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1.
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Please
revise your filing top disclose if there were any disagreements through
any subsequent interim periods proceeding such resignation, declination
or
dismissal with the former accountant on any matter of accounting
principles or practices, financial statement disclosure, or auditing
scope
or procedures, with disagreement(s), if not resolved to the satisfaction
of the former accountant, would have caused it to make reference
to the
subject matter of the disagreemt(s) in connection wit6h its reports,
Refer
to item 304(a)(1)(iv) of Regulation
S-B.
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2.
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In
addition, please revise your disclosure in paragraph 5 and 6 to disclose
that there were no reportable events or you did not consult JSW through
any subsequent interim periods proceeding resignation, declination
or
dismissal with the former
accountant.
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3.
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We
note that your independent registered public accountant is licensed
in the
state of Florida while your principal office is in the state of
California. Confirm to us that Jewett, Schwartz, Wolfe &
Associates is in compliance with the California state licensing
requirements. IN the event of noncompliance with California
state requirement, you should consider the need for additional disclosure
or obtaining audit service from a different
practitioner.
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4.
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To
the extent that you make changes to the Form 8-K to comply with the
our
comments, please obtain and file an updated Exhibit 16 letter from
the
former accountants stating whether the accountant aggress with the
statements made in your revised Form 8-K. We note your
disclosure that you did not receive a letter from Meylers prior to
filing
your Form 8K.
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•
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the
Company is responsible for the adequacy and accuracy of the disclosure
in
the filings;
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staff
comments or changes to disclosure in response to staff comments
do not
foreclose the Commission from talking any action with respect to
the
fling; and
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•
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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.
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Yours
truly,
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By:
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/s/
Michael Chermak
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Michael
Chermak
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CEO
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