CLIFFORD L. NEUMAN, P.C.
Attorney at Law
TEMPLE-BOWRONHOUSE
1507 PINESTREET
BOULDER,COLORADO80302
Telephone: (303) 449-2100
Facsimile: (303) 449-1045
E-mail: clneuman@neuman.com
August 30, 2005
VIA EDGAR AND FACSIMILE
Errol Sanderson, Staff Attorney
United States Securities and Exchange Commission
450 Fifth Street N.W.
Mail Stop 70-10
Washington, D.C. 20549
Re: | Ikona Gear International, Inc. | |
Registration Statement on Form SB-2 | ||
File No. 333-126523 |
Dear Mr. Sanderson:
On behalf of Ikona Gear International, Inc. (the "Company"), please be advised that at the request of the Commission, the Company has recontacted the Swiss banks that are included among the Selling Securityholders listed in the Registration Statement.
In each instance, the Company has been advised that the securities were acquired by the Swiss bank in a discretionary account of pooled investors. As such, the Swiss bank, as an entity, exercises voting and investment power with respect to the securities.
In view of this information, it would appear that the current disclosure in the Registration Statement conforms with the requirements of Item 507 of Regulation SB.
Please advise if the Commission has further comments regarding this matter. We are prepared to file an amendment to the Registration Statement as soon as this issue is resolved.
Thank you very much.
Sincerely,
/s/ Clifford L. Neuman
Clifford L. Neuman
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