Wheelchair ADL Solutions Corporation
1324 N. Liberty Lake Rd. #169 |
Liberty Lake, WA 99019 |
May 2, 2012
United States Securities and Exchange Commission
Attn: Ms. Amanda Ravitz, Assistant Director; and Mr. Tom Jones, Staff Attorney
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-4631
Re:
Wheelchair ADL Solutions Corporation
Amendment No. 3 to Registration Statement on Form S-1
Filed March 23, 2012
File No. 333-178417
Dear Ms. Ravitz and Mr. Jones:
We are writing in response to your discussion with our counsel regarding inclusion of clarifying language regarding Matthew Allen’s oral agreement to fund our potential capital shortfalls. We have added such language to the “Plan of Operation” subsection at the beginning of our “Management’s Discussion and Analysis of Fiscal Condition and Results of Operation” (“MD&A”) section.
Additionally, we have also included financial statements for our first fiscal quarter ending February 29, 2012. Finally, per your conversation with our counsel wherein you indicated that the Commission would likely have additional comments regarding the JOBS Act and the company’s “emerging growth company” status, we have added additional language regarding the same to our risk factor disclosure and MD&A sections.
Please feel free to contact our counsel, Vincent & Rees, L.C. at (801) 303-5730 with any questions or concerns.
Sincerely,
Matthew Allen
By: /s/ Matthew Allen
Matthew Allen, Chairman and President
