Lang Michener LLP
BARRISTERS & SOLICITORS
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File Number: 57532-0018-Letter
Web site: www.langmichener.com
Direct Line: (604) 691-7445
Direct Fax Line: (604) 893-2679
E-Mail: tdeutsch@lmls.com
October 27, 2006
Delivered and as filed on EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 3561
450 Fifth Street, N.W.
Washington, D.C.
U.S.A., 20549-0405
Attention: Mr.H. Christopher Owings, Assistant Director
Dear Mr. Owings:
Re:
Naturally Advanced Technologies Inc. (f/k/a Hemptown Clothing Inc.) (the "Company")
Form 10-KSB for the Fiscal Year Ended December 31, 2004 and
Forms 10-QSB for the Fiscal Quarters Ended March 31, 2005, June 30, 2005 and September 30, 2005
File No. 0-50367
Follow-up response to SEC Comment Letter dated April 26, 2006
We are counsel for the above-referenced Company and, as such, we are writing in furtherance of our most recent letter of May 31, 2006 in this matter wherein we acknowledged receipt, on behalf of the Company, the Company's prior receipt of the follow-on comments (to the Company's draft response letter with enclosures dated February 9, 2006) of the reviewing staff (the "Staff") of the Securities and Exchange Commission (the "SEC") in connection with the Company's above-referenced financial statement disclosure documents (collectively, the "Financial Statements") as set forth in the SEC's second comment letter dated April 26, 2006 (the "SEC Letter") in this matter.
In this regard we confirm, on behalf of the Company, and, as we understand, which has recently been discussed directly by the Company with SEC Staff, that while the Company is still in the midst of addressing and answering each of the follow-on comments put forward by Staff in the SEC Letter, due to certain and additional delays experienced to date by the Company in having to address the Staff's comments in connection with each such Financial Statement, and with both the Company's current and previous independent auditors, the Company is hereby seeking a further and brief extension to the Staff's originally requested response date in this matter.
As a consequence we hereby confirm, on behalf of the Company, that we are informed that the Company should be in a position to provide the SEC with a complete and follow-up response to the SEC Letter, together with the necessary and EDGAR-filed amended Financial Statement document disclosure, by no later than the close of business on Friday, November 3, 2006. Should the Company determine, prior to November 3, 2006, that any of the Staff's follow-on comments remain outstanding by that date, we confirm that we are informed by the Company that the Company will still respond to whatever it has been able to determine and confirm at that time.
On behalf of the Company we sincerely thank and appreciate the SEC's attention to and anticipated cooperation in this matter and, in the interim, we remain,
Yours very truly,
Thomas J. Deutsch
forLang MichenerLLP
TJD
ec: The Company