National Bank of Anguilla Corporate Building, 1st Floor, St Mary's Road
TV1 02P, The Valley, Anguilla, British West Indies
Ph: (264) 461-2646 Fax:+44 845 280 3297
1166 Alberni St, Suite 1405, Vancouver, BC V6E-3Z3, Canada
Ph: 604-694-0300 Fax:604-694-0301
Juan Migone
Division of Corporation Finance
United States Securities and Exchange Commission
Washington DC 20549-0402
United States of America
December 7, 2009
Dear Sirs
RE Bingo.com, Ltd. Form 10-K for the year ended December 31, 2008
Filed March 2009, File Number : 333-120120-01
In accordance with your letter September 17, 2009, our response dated October 1, 2009 and our telephone conversations, we have made the following changes to our Form 10-K for the year ended December 31, 2008.
1. Auditors Report
The audit report has been amended to mention the substantial doubt about the Company's ability to continue as a going concern.
2. Consolidated Statement of Operations,
These has been amended to conform to a Service Company consolidated statement of operations and the gross profit line has been removed.
3. & 4. Sales of US players and related assets.
The Allowance for doubtful accounts in the balance sheet has been amended to include the remaining amount due from the sale of US Players. In addition Note 3 has been amended to include the fact there is no set period of repayment and the balance due is interest free and that the Company has fully provided for the amount due.
5, 6, & 7. Domain Name Rights and Intangible Assets
In the accounting policy notes we have included the following sentence "The Company determine that as a result of level 3 unobservable inputs in accordance with SFAS 157 Fair Value Measurements, that the fair value of the domain name exceeded the carrying value and therefore no impairment existed for the years presented."
As discussed, we have been offered amounts well in excess of the carrying value of the domain name.
8. Controls & Procedures
We have included wording that the management has undertaken a management assessment on internal controls.
Finally in response to your letter the Company acknowledges the following:
- 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 defense in any proceeding initiated by the Commission or any person under the federal securities law of the United States.
If you would like to discuss these matter further please do not hesitate to contact us.
Yours sincerely
/s/ T. M. Williams /s/ H W Bromley
Tarrnie Williams Henry Bromley
Chief Executive Officer Chief Financial Officer
Cc Irene Salum
Dohan and Company CPAs
