-----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, Ws0TKC/pByMhk3bL+/rrJJgurrGkxXkfHt59/VD/Nxqjkc4/+BHo+PnORGoGjSZy mqJU/hyUD1up1hAjfWaLSg== 0000000000-05-030841.txt : 20060919 0000000000-05-030841.hdr.sgml : 20060919 20050617181815 ACCESSION NUMBER: 0000000000-05-030841 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050617 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: ADVANCED ID CORP CENTRAL INDEX KEY: 0001005356 STANDARD INDUSTRIAL CLASSIFICATION: SEMICONDUCTORS & RELATED DEVICES [3674] IRS NUMBER: 460439668 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 6143 -- 4TH STREET SE, SUITE 14 CITY: CALGARY STATE: A0 ZIP: T2H 2H9 BUSINESS PHONE: 403-264-6300 MAIL ADDRESS: STREET 1: 6143 -- 4TH STREET SE, SUITE 14 CITY: CALGARY STATE: A0 ZIP: T2H 2H9 FORMER COMPANY: FORMER CONFORMED NAME: USA SUNRISE BEVERAGES INC DATE OF NAME CHANGE: 19980929 LETTER 1 filename1.txt June 17, 2005 Mail Stop 0610 Barry Bennett Chief Executive Officer Advanced ID Corporation 6143-4 Street SE, Suite 14 Calgary, Alberta Canada T2H 2H9 Re: Advanced ID Corporation Amended Preliminary Proxy Statement on Schedule 14A Filed June 14, 2005 File No. 0-24965 Dear Mr. Bennett: This is to advise you that we have reviewed only the narrative portions of the above filing and have not conducted an accounting review of any of your company`s financial statements. We have the following comments on your filing. We anticipate at this time that no further review of your proxy statement will be made other than a review of your responses to these comments. Note that we may have further comments on these issues. All persons who are by statute responsible for the adequacy and accuracy of the filing are urged to be certain that all required information has been included. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Discussion of Proposals by the Board Proposal 1: Election of Directors 1. We note your response to comment 4. We also understand from our recent telephone conversations with counsel that cumulative voting is required under the South Dakota Constitution. Accordingly, please revise to provide appropriate disclosure regarding the nature, procedures for exercise, and effect of those cumulative voting rights. In addition, if shareholders of the Nevada corporation will not have cumulative voting rights, please include appropriate disclosure. * * * * As appropriate, please revise your proxy statement in response to these comments and to update your disclosure. As required by Rule 14a-6(h), please provide us with marked copies of the revised proxy statement to expedite our review. Please furnish a cover letter with your revised proxy statement that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your revised proxy statement and responses to our comments. Please contact the undersigned at (202) 551-3607 with any questions. Sincerely, David Ritenour Special Counsel cc (via fax): Jody Walker, Esq. (fax: 303-220-9902) ?? ?? ?? ?? Advanced ID Corporation June 17, 2005 Page 1 -----END PRIVACY-ENHANCED MESSAGE-----