0001387308-14-000058.txt : 20140630 0001387308-14-000058.hdr.sgml : 20140630 20140529150326 ACCESSION NUMBER: 0001387308-14-000058 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20140529 FILER: COMPANY DATA: COMPANY CONFORMED NAME: AXIM INTERNATIONAL INC. CENTRAL INDEX KEY: 0001514946 STANDARD INDUSTRIAL CLASSIFICATION: REFUSE SYSTEMS [4953] IRS NUMBER: 274092986 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 18 E. 50TH STREET STREET 2: 5TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10022 BUSINESS PHONE: 1-702-750-8242 MAIL ADDRESS: STREET 1: 18 E. 50TH STREET STREET 2: 5TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10022 CORRESP 1 filename1.htm corrtodo.htm
                           
                               AXIM International, Inc.
18 E 50th St 5th Floor
New York, NY 10022













May 28, 2014

Ms. Jenn Do
SECURITIES AND EXCHANGE COMMISSION
Division of Corporation Finance
100 F Street, N.E., Mail Stop 7010
Washington, D.C. 20549

Re:           AXIM International, Inc. (the “Company”)
Form 8-K Item 4.01
Filed May10, 2014
File No.  000-54296

Dear Ms. Do:

Please allow this to respond to your letter dated May 28, 2014, regarding the above referenced Company.  This letter keys to your comments and our responses.  We have included the Company acknowledgement at the end of this letter.

1.  We have revised our filing to disclose that the PCAOB has revoked the registration of Jeffrey & Company.

2.  We have revised our filing to provide the disclosures required by Item 304(a)(1)(ii) and to state that the audit reports contained a going concern explanatory paragraph.

3.   We have filed an updated Exhibit 16 letter.
 
 
 




ACKNOWLEDGEMENT

AXIM International, Inc. (the “Company”) is responsible for the adequacy and accuracy of the disclosure in the filing;

Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 
AXIM International, Inc.
   
 /s/
Dr. George E. Anastassov
By:
Dr. George E. Anastassov
Its:
Chief Executive Officer