[Letterhead of Emtec, Inc.]
July 27, 2005
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549-3628
Attn: Daniel F. Duchovny
Attorney-Advisor
Office of Mergers and Acquisitions
RE: Emtec, Inc.
Schedule 14F-1 filed July 18, 2005
SEC File No. 005-44028
Ladies and Gentlemen:
This letter is in response to the Staff’s letter dated July 25, 2005 concerning the Schedule 14F-1 of Emtec, Inc. (the “Company”). The response is preceded by the full text of the Staff’s comment.
Schedule 14F-1
1. | Please provide the information required by Item 7(h) of Schedule 14A. |
Response:
Reference is made to page 11 of the Schedule 14F-1.
The Company acknowledges that:
• | 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 laws of the United States. |
Please call Ira Roxland of Sonnenschein Nath & Rosenthal LLP at (212) 768-6999 if you have any further questions or comments.
Sincerely,
/s/ Sam Bhatt
Sam Bhatt
Vice President-Finance