-----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, VxKvJdyrAsnTyv2+va9sZyxRGcoAg5+CPOQrBet67FRyEoWbKucNPTteQKgfQr2R TEy0TGDJYQK89e6dDxdtcw== 0000768216-10-000021.txt : 20100604 0000768216-10-000021.hdr.sgml : 20100604 20100402153400 ACCESSION NUMBER: 0000768216-10-000021 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 3 FILED AS OF DATE: 20100402 FILER: COMPANY DATA: COMPANY CONFORMED NAME: BLUEGATE CORP CENTRAL INDEX KEY: 0000768216 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-BUSINESS SERVICES, NEC [7389] IRS NUMBER: 870565948 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 701 NORTH POST OAK ROAD STREET 2: SUITE 600 CITY: HOUSTON STATE: TX ZIP: 77024 BUSINESS PHONE: 7136861100 MAIL ADDRESS: STREET 1: 701 NORTH POST OAK ROAD STREET 2: SUITE 600 CITY: HOUSTON STATE: TX ZIP: 77024 FORMER COMPANY: FORMER CONFORMED NAME: CRESCENT COMMUNICATIONS INC DATE OF NAME CHANGE: 20010921 FORMER COMPANY: FORMER CONFORMED NAME: BERENS INDUSTRIES INC DATE OF NAME CHANGE: 19990823 FORMER COMPANY: FORMER CONFORMED NAME: NATIONAL AIR CORP DATE OF NAME CHANGE: 19970521 CORRESP 1 filename1.htm correspcover040210.htm
[Correspondence to the SEC]

BLUEGATE CORPORATION
701 North Post Oak, Road, Suite 600
Houston, Texas 77024
voice:  (713) 686-1100
fax:  713-682-7402

April 2, 2010

H. Christopher Owings
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
Washington, D. C. 20549-3561

Re: Bluegate Corporation
      Post-Effective Amendment to Form S-1filed March 22, 2010
      File No. 333-145492

Dear Mr. Owings:

This letter is in response to your comments contained in the letter to our Chief Executive Officer, Stephen J. Sperco, dated April 1, 2010.

Enclosed please find our acknowledgement letter and memorandum of responses.


Respectfully yours,


/s/ Charles E. Leibold
Charles E. Leibold
Chief Financial Officer
 CORRESP 2 filename2.htm correspack040210.htm
[Correspondence to the SEC]

BLUEGATE CORPORATION
701 North Post Oak, Road, Suite 600
Houston, Texas 77024
voice:  (713) 686-1100
fax:  713-682-7402

April 2, 2010

H. Christopher Owings
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
Washington, D. C. 20549-3561

Re: Bluegate Corporation
      Post-Effective Amendment to Form S-1filed March 22, 2010
      File No. 333-145492

Dear Mr. Owings:

Company Acknowledgements

The Company submits the following acknowledgements:

Bluegate Corporation is responsible for the adequacy and accuracy of the disclosure in the filing.
 
 
Bluegate Corporation acknowledges that 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.

Bluegate Corporation 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.

Respectfully yours,


/s/ Charles E. Leibold
Charles E. Leibold
Chief Financial Officer
 CORRESP 3 filename3.htm correspmemo040210.htm
[Correspondence to the SEC]

BLUEGATE CORPORATION

Memorandum of Responses to SEC Comment letter dated April 1, 2010


SEC comment 1 – Cover Page

1. Please revise to include the amendment number. Refer to Rule 470 of the Securities Act.

Bluegate response to comment 1 -

The cover page has been revised to include the amendment number.

SEC comment 2 – Cover Page

2. Please revise your SIC number (it appears it should be 7389) or advise.

Bluegate response to comment 2 –

The SIC number has been revised to 7389.

SEC comment 3 – Cover Page

3. Please revise to check the appropriate box regarding your filing status as a smaller reporting company.

Bluegate response to comment 3 –

The cover page has been revised and the appropriate box regarding our filing status as a smaller reporting company has been checked.

SEC comment 4 – Cover Page

4. We note that you have included the delaying amendment language contemplated by Rule 473 under the Securities Act on the cover page of the registration statement. Please note, however, that the delaying amendment language you have included is not applicable to a post-effective amendment. Refer to Section 8(c) of the Securities Act.

Bluegate response to comment 4 –

The delaying amendment language contemplated by Rule 473 has been deleted.

BLUEGATE CORPORATION

SEC comment 5 – Exhibits

5. Please revise to incorporate by reference your previously filed legal opinion.

Bluegate response to comment 5 –

The previously filed legal opinion has been incorporated by reference.
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