February 6, 2007
United States
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 205049
Attention: Mike Volley and Amit Pande
Original via post – copy via facsimile
Dear Sirs:
Re:
Westsphere Asset Corporation, Inc.
Form 10-KSB for Fiscal Year End December 31, 2004
Filed April 15, 2005
File No. 0-32051
Further to your correspondence dated January 8, 2007 and subsequent discussion with Westsphere Vice President Sonia Dreyer we are answering the comments outlined following:
Note 4 – Investments, page F-10
Item #2. This is to acknowledge that we will revise our future filings to present a roll forward that includes additions to and impairments of major intangible asset classes.
In connection with responding to your comments, we acknowledge that:
·
The Corporation 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 defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely,
Douglas N. Mac Donald, President & CEO
Westsphere Asset Corporation, Inc.