0001013762-10-000440.txt : 20160209 0001013762-10-000440.hdr.sgml : 20160209 20100302173319 ACCESSION NUMBER: 0001013762-10-000440 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100302 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Forex International Trading Corp. CENTRAL INDEX KEY: 0001471781 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-PREPACKAGED SOFTWARE [7372] IRS NUMBER: 270603137 STATE OF INCORPORATION: NV FISCAL YEAR END: 0415 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O OLGA SASHCENKO STREET 2: 23129 CAJALCO RD CITY: PERRIS STATE: CA ZIP: 92570 BUSINESS PHONE: 888-333-8075 MAIL ADDRESS: STREET 1: C/O OLGA SASHCENKO STREET 2: 23129 CAJALCO RD CITY: PERRIS STATE: CA ZIP: 92570 FORMER COMPANY: FORMER CONFORMED NAME: Forex International Trading Corp. DATE OF NAME CHANGE: 20090908 CORRESP 1 filename1.htm Unassociated Document
Law Offices of Stephen M. Fleming PLLC
49 FRONT STREET SUITE 206  ROCKVILLE CENTRE NEW YORK 11570
TEL  516 833-5034   FAX  516 977 1209   WWW.FLEMINGPLLC.COM

March 2, 2010

Kathleen Collins, Division of Corporation Finance
U. S. Securities and Exchange Commission
Division of Corporation Finance
One Station Place
100 F Street
Washington, D.C. 20549

Re:     Forex International Trading Corp.
Amendment No. 5 to Registration Statement on Form S-1
Filed February 24, 2010
File No. 333-161795

Dear Ms. Collins:

 
This firm is counsel to Forex International Trading Corp. (the “Company”). Below please find our responses to your February 26, 2010 comment letter.
 

 
Dilution, page 9

1.  
Revise your dilution information to correct the following:

·  
The net tangible book value per share at October 31, 2009 included throughout the tables should be bracketed to indicate that you were in a deficit position at that date;
·  
Correct your calculations of the “increase per share attributed to this offering” as a result of changing the net tangible book value to a deficit and also to remove the negative signs; and
·  
The “pro forma net tangible book value per share after offering” calculated based on the maximum number of shares being solids not a deficit and therefore the negative sign should be removed from your disclosures in the second table on page 9.  As a result of this change, the increase per share attributing to this offering will change to .002167 and the disclosures regarding this change should be corrected throughout.

Response

We have made the requested changes.


***

Should you have any questions, please do not hesitate to contact the undersigned at 516-833-5034.
 
 
Sincerely,
  
       
 
By:
/s/ Stephen M. Fleming  
   
Stephen M. Fleming