Unassociated Document
ROBERT
O. KNUTSON
Attorney
at Law
9372
Creekwood Drive
|
Phone:
(952)941-0908
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Eden
Prairie, MN 55347
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Fax:
(952)941-2744
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January
14, 2011
Division
of Corporation Finance
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Re:
Response to SEC Letter dtd 12/30/10
|
U.
S. Securities and Exchange Commission
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to
Viper Powersports Inc.
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Washington,
D.C. 20549
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Attn:
Doug Jones
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|
Dear
Commission:
This
letter is in response to your comment letter to Viper Powersports Inc. (“Viper”)
dated
December 30, 2010 and addressed to our CFO Jerome Posey. I am the Chairman,
Secretary and Legal Counsel of Viper and am the person who will respond to you
on these matters.
As stated
in my phone conference with Mr. Jones which occurred within 10 business days of
receipt of your comment letter, we are working on responses to your various
comments including having our outside auditor engaged in this matter. We intend
to have our responses sent to you in an Edgardized format by the end of this
present month January
2011. As stated in our phone conference and requested in your comment letter,
Viper confirms that it will revise and amend its filings to conform with your
comments unless we believe your comments do not apply to our fact
situation.
As
requested at the end of your comment letter, Viper acknowledges the
following:
(i)Viper
is responsible for the adequacy and accuracy of disclosures in its
filings;
(ii) SEC
staff comments or changes to disclosure in response to staff comments do not
foreclose your Commission from taking any action with respect to our filings;
and
(iii)
Viper may not assert staff comments as a defense in any proceeding initiated by
your Commission or any person under the federal securities laws of the United
States.
Sincerely,
/s/
Robert O.
Knutson
Robert O.
Knutson
cc:
Jerome L. Posey, CFO