0001165527-14-000724.txt : 20150203
0001165527-14-000724.hdr.sgml : 20150203
20141224095547
ACCESSION NUMBER: 0001165527-14-000724
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20141224
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: GLOBAL EQUITY INTERNATIONAL INC
CENTRAL INDEX KEY: 0001533106
STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-MANAGEMENT CONSULTING SERVICES [8742]
IRS NUMBER: 273986073
STATE OF INCORPORATION: NV
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 907 SOUTH RIVERSIDE DRIVE
CITY: INDIALANTIC
STATE: FL
ZIP: 32903
BUSINESS PHONE: 3215490628
MAIL ADDRESS:
STREET 1: 907 SOUTH RIVERSIDE DRIVE
CITY: INDIALANTIC
STATE: FL
ZIP: 32903
CORRESP
1
filename1.txt
Global Equity International, Inc.
X3 Jumeirah Bay, Office 3305
Jumeirah Lake Towers,
Dubai, UAE
December 24, 2014.
Securities and Exchange Commission,
Division of Corporation Finance,
100 F Street, N.E.,
Washington, D.C. 20549.
Attention: Mr. Robert F. Telewicz, Jr.
Senior Staff Accountant.
Ms. Shannon Sobotka. Staff Accountant.
Re: Global Equity International, Inc.
Form 10-K for the fiscal year ended December 31, 2013
Filed on March 31, 2014
File No. 000-54557
Dear Madam and Sir,
This letter is a further response to your letter to this registrant of
December 19, 2014, regarding the above-referenced matter ("Comment Letter"). The
purpose of this letter is to resolve Staff comments in the Comment Letter.
Our responses to the Comment Letter are as follows:
Form 10-K for the year ended December 31, 2013
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 28
Results for the Twelve Month's Ended December 31, 2013, page30
1) We have reviewed your response to our prior comment 3. Item 10(e) of
Regulation S-K indicates that an item cannot be identified as non-recurring
when the nature of the charge or gain is such that it is reasonably likely
to recur within two years or there was a similar charge or gain within the
prior two years. Given that the company has incurred similar charges in the
prior year please revise your disclosure in future filings to remove the
reference to non-recurring.
Response:
We will revise our disclosure in future filings ensuring to remove the
"non-recurring" reference.
In responding to your comments, we acknowledge that:
* 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 defence in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Please address any further comments to our attorney, David E. Wise, Esq.
Mr. Wise's contact information is set forth below:
Law Offices of David E. Wise
Attorney at Law
The Colonnade
9901 IH-10 West, Suite 800
San Antonio, Texas 78230
Telephone: (210) 558-2858
Facsimile: (210) 579-1775
Email: wiselaw@verizon.net
Sincerely,
/s/ Enzo Taddei
-------------------------------
Enzo Taddei
Chief Financial Officer
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