-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, QZtElcKJjfSnxu9l2UDNKt9COy0GKL+CVJx6u6vxll1DNU7qWIkV4S5q8cLbZkjP fFzUwIsMPB4wcZbeLxsN5w== 0001437904-10-000039.txt : 20100809 0001437904-10-000039.hdr.sgml : 20100809 20100602115436 ACCESSION NUMBER: 0001437904-10-000039 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100602 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Promap Corp CENTRAL INDEX KEY: 0001477009 STANDARD INDUSTRIAL CLASSIFICATION: OIL, GAS FIELD SERVICES, NBC [1389] IRS NUMBER: 208096131 STATE OF INCORPORATION: CO FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 7060B SOUTH TUCSON WAY CITY: CENTENNIAL STATE: CO ZIP: 80112 BUSINESS PHONE: (720) 889-0510 MAIL ADDRESS: STREET 1: 7060B SOUTH TUCSON WAY CITY: CENTENNIAL STATE: CO ZIP: 80112 CORRESP 1 filename1.txt JIN SCHAUER & SAAD LLC Attorneys at Law Telephone Suite 2700 South Tower Facsimile (720) 888-2211 600 Seventeenth Street (720) 889-2222 Denver, Colorado 80202-5427 June 2, 2010 H. Roger Schwall, Assistant Director Division of Corporation Finance United States Securities and Exchange Commission 100 F Street Washington, D.C. 20549 Re: Promap Corporation Amendment No. 1 to Registration Statement on Form S-1 Filed April 21, 2010 File No. 333-163342 Dear Mr. Schwall: This letter will serve as a response and/or explanation with respect to the comments in your letter dated May 6, 2010 (the "Comment Letter") regarding Promap Corporation ("Promap" or the "Company"). The entire text of the comments contained in your comment letter has been reproduced in this letter for ease of reference. A response to each comment is set forth immediately below the text of the comment. Legal Proceedings, page 20 1. Please revise your disclosure to provide the information required by Item 401(f) of Regulation S-K for the past ten years. If no such events occurred, please so state. We have added disclosure under Legal Proceedings that there have not been any such events during the last ten years. Directors, Executive Officers, Promoters and Control Persons, page 21 Background Information About Our Officers and Directors, page 21-22 2. On an individual basis for each director, enhance your disclosure to specifically state why the person's particular and specific experience, qualifications, attributes or skills led the board to conclude that such person should serve as a director of the company, in light of the company's business and structure, as of the time that the registration statement was filed. Refer to Item 401(e)(1) of Regulation S-K. We have added the additional disclosure for the Company's two directors. Customers, page 28 3. We note your response to our prior comment seven and your related disclosure that your "prices are agreed to in advance" and that your rates are "periodically matched by the affiliates with third party rates and are determined to be comparable." In this regard, supplementally tell us the number of third parties determined to be comparable to you and how this determination was reached. Also explain the criteria used to determine that the affiliate rates are comparable to the third party rates. There are only a small number of competitors in the Company's market space, perhaps 5 or 6 that they are aware of. The different affiliates check their comparison rates independently and periodically with other vendors such as Pennwell, OGI and Digital Data. The criteria used to price the Company's custom maps is determined by quality, the number of informational layers, the complexity of GIS and geospatial data, the amount of time involved in drafting and creating computer files and size of the final product. Pricing for each element is determined in advance and agreed to prior to commencing production of each map. Thank you for your attention to this matter. Please contact the undersigned if you have any questions or need any additional information. Very truly yours, JIN SCHAUER & SAAD LLC By /s/ Jon D. Sawyer Jon D. Sawyer -----END PRIVACY-ENHANCED MESSAGE-----