-----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, PMV/Ay0DpGBUxEda/TR/3oZb4OCstShZpmQjFTs7OhLjRs1f5Srgq+RKAIoUmmFa eeT8mOAWQcrITS6AZdevfQ== 0000849401-05-000010.txt : 20060614 0000849401-05-000010.hdr.sgml : 20060614 20050818150144 ACCESSION NUMBER: 0000849401-05-000010 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050818 FILER: COMPANY DATA: COMPANY CONFORMED NAME: ADM TRONICS UNLIMITED INC/DE CENTRAL INDEX KEY: 0000849401 STANDARD INDUSTRIAL CLASSIFICATION: ADHESIVES & SEALANTS [2891] IRS NUMBER: 221896032 STATE OF INCORPORATION: DE FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 224 S PEGASUS AVE CITY: NORTHVALE STATE: NJ ZIP: 07647 BUSINESS PHONE: 2017676040 MAIL ADDRESS: STREET 1: 224 S PEGASUS AVE CITY: NORTHVALE STATE: NJ ZIP: 07647 CORRESP 1 filename1.txt August 18, 2005 VIA EDGAR Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Ryan Rohn, Staff Accountant Re: ADM Tronics Unlimited, Inc. Current Report on Form 8-K, Item 4.01 Filed August 11, 2005 File No. 000-17629 Dear Mr. Rohn: Accompanying this letter for filing pursuant to the Securities Actof1933, as amended, is a conformed copy of Amendment No. 1 to the above-referenced Current Report on Form 8-K (the "Form 8-K"). Amendment No. 1 is being filed in response to the Staff's letter of comment dated August 12, 2005 (the "Comment Letter"). Manually executed signature pages and consents have been executed prior to the time of this electronic filing of Amendment No. 1. Attached to this letter as Appendix A is a memorandum in response to the Comment Letter. Attached to this letter as Appendix B is a written statement from of ADM Tronics Unlimited, Inc. (the "Company") pursuant to which the Company acknowledges that: o the Company is responsible for the adequacy of the disclosure in the Form 8-K; o Staff comments or changes to disclosure in response to Staff comments in the Form 8-K reviewed by the Staff do not foreclose the Securities and Exchange Commission from taking any action with respect to the Form 8-K; and o the Company may not assert Staff comments as a defense in any proceeding initiated by the Securities and Exchange Commission or any person under federal securities laws of the United States. Very truly yours, /s/ Steven M. Skolnick Steven M. Skolnick Enclosures cc: Mr. Andre' DiMino - ADM Tronics Unlimited, Inc. ADM Tronics Unlimited, Inc. Current Report on Form 8-K Memorandum in Response to SEC Letter of Comment dated August 12, 2005 The following are responses to the Staff's letter of comment, dated August 12, 2005 (the "Comment Letter"), which have been authorized by ADM Tronics Unlimited, Inc. (the "Company"). To assist the Staff's review, the responses are numbered to correspond to the numbered paragraphs in the Comment Letter. 1. Amend your Form to state whether the former accountant resigned, declined to stand for re-election or was dismissed. Refer to Item 304(a)(1)(i) of Regulation S-B. The Company is filing herewith Amendment No. 1 to Current Report on Form 8-K/A ("Form 8-K/A") to amend the Company's Current Report on Form 8-K filed with the Securities and Exchange Commission on August 11, 2005, to state that on August 5, 2005, the Company, was advised that, effective as of August 1, 2005, its certifying accountants, Weinick Sanders Leventhal & Co., LLP, ceased operations and as a result, resigned as the Company's certifying accountants. 2. Amend your Form to indicate whether the board of directors recommended or approved the decision to change accountants. Refer to Item 304(a)(1)(iii) of Regulation S-B. The Company has included in the Form 8-K/A a statement that the Company's board of directors approved the Company's appointment of Raich Ende Malter & Co. LLP as its certifying accountants to replace Weinick Sanders Leventhal & Co., LLP. 3. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your revised Form 8-K. The Company has attached as Exhibit 16.1 to the Form 8-K/A an updated letter from Weinick Sanders Leventhal & Co., LLP stating that Weinick Sanders Leventhal & Co., LLP agrees with the statements made in the Form 8-K/A. Appendix A ADM Tronics Unlimited, Inc. 224-S Pegasus Avenue Northvale, NJ 07647 August 18, 2005 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Ryan Rohn, Staff Accountant Re: ADM Tronics Unlimited, Inc. Current Report on Form 8-K, Item 4.01 Filed August 11, 2005 File No. 000-17629 Dear Mr. Rohn: Reference is hereby made to (i) Amendment No. 1 to the above-referenced Current Report on Form 8-K (the "Form 8-K") of ADM Tronics Unlimited, Inc. (the "Company") and (ii) the Staff's letter of comment dated August 12, 2005 (the "Comment Letter"). In accordance with the Comment Letter, the Company hereby acknowledges that: o the Company is responsible for the adequacy of the disclosure in the Form 8-K; o Staff comments or changes to disclosure in response to Staff comments in the Form 8-K reviewed by the Staff do not foreclose the Securities and Exchange Commission from taking any action with respect to the Form 8-K; and o the Company may not assert Staff comments as a defense in any proceeding initiated by the Securities and Exchange Commission or any person under federal securities laws of the United States. Very truly yours, ADM TRONICS UNLIMITED, INC. By: /s/ Andre' DiMino Andre' DiMino President -----END PRIVACY-ENHANCED MESSAGE-----