![[tdc_coresp001.jpg]](https://capedge.com/proxy/CORRESP/0001393905-14-000324/tdc_coresp001.jpg)
May 20, 2014
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attn: Christie Wong, Staff Accountant
Emily Drazan, Staff Attorney
Paul Fischer, Staff Attorney
Re: TheDirectory.com, Inc. (formally known as Elysium Internet, Inc.)
Amendment No.3 to Registration Statement on Form 10-12G
Filed April 30, 2014, Amendment No.4 to Registration Statement on Form 10-12G
Filed May 6, 2014
File No. 000-31431
Dear Ms. Wong, Ms. Drazan, and Mr. Fischer:
I am Chief Executive Officer for the TheDirectory.com, Inc. (the “Company”). Set forth below is the Company’s response to comments received from the staff of the Securities and Exchange Commission (the “staff”) in their letter dated May 19, 2014. The numbering of the response corresponds to the numbering of the comment in the letter from the staff.
General
Comment 1: We note in your response to comment 2 you indicate that “the acquired technology based asset is a set of customer designed PHP and database source code developed to operate and power directory……and add layers of functionality as they are needed.” Because the described asset is technology based and therefore subject to obsolescence, we believe it has a finite useful life and should be amortized pursuant to the guidance in ASC 350 30-35-3e. Please revise your accounting policy accordingly.
Response 1: Pursuant to our phone call on Monday May 19th, the Company agrees that in its next quarterly form 10Q filing for the quarter ending May 31, 2014, the Company will revise its accounting language and financial statements to begin amortizing its acquired technology based asset pursuant to the guidance in ASC 350-30-35-3e.
If you have further questions or comments, please feel free to contact me. I am happy to cooperate in any way I can.
Regards,
/s/ Scott Gallagher
Scott Gallagher
Chief Executive Officer