 A PROFESSIONAL CORPORATION 3 Triad Center Suite 500 Salt Lake City, Utah 84180 T : (801) 532-7080 F : (801) 596-1508 www.strongandhanni.com | GLENN C. HANNI, P.C. HENRY E. HEATH PHILIP R. FISHLER ROGER H. BULLOCK R. SCOTT WILLIAMS SCOTT R. JENKINS PAUL M. BELNAP STUART H. SCHULTZ BRIAN C. JOHNSON 2 PAUL W. HESS STEPHEN J. TRAYNER STANFORD P. FITTS 7 BRADLEY W. BOWEN PETER H. CHRISTENSEN 5 ROBERT L. JANICKI H. BURT RINGWOOD CATHERINE M. LARSON KRISTIN A. VANORMAN PETER H. BARLOW GRADEN P. JACKSON 3 H. SCOTT JACOBSON MICHAEL J. MILLER 6 | ANDREW D. WRIGHT MICHAEL L. FORD 4 BYRON G. MARTIN BENJAMIN P. THOMAS SUZETTE H. GOUCHER JACOB C. BRIEM 1 LANCE H. LOCKE A. JOSEPH SANO JAMES C. THOMPSON PETER J. BAXTER JENNIFER R. CARRIZAL LORI A. JACKSON BRYANT J. McCONKIE WILLIAM B. INGRAM JEREMY G. KNIGHT RYAN P. ATKINSON JARED T. HALES JEFFERY J. OWENS ANDREW B. McDANIEL SADÉ A. TURNER AREK E. BUTLER PAUL W. JONES | 1 ALSO MEMBER ARIZONA BAR 2 ALSO MEMBER CALIFORNIA BAR 3 ALSO MEMBER COLORADO BAR 4 ALSO MEMBER DISTRICT OF COLUMBIA BAR 5 ALSO MEMBER OREGON BAR 6 ALSO MEMBER WASHINGTON BAR 7 ALSO MEMBER WYOMING BAR ESTABLISHED 1888 ______ GORDON R. STRONG (1909-1969)  |
October 10, 2008
Christine Davis
Assistant Chief Accountant
Securities and Exchange Commission
450 5th Street NW, Mail Stop 4561
Washington, DC 20549
Re: InMedica Development Corporation
Form 10-K/A for Fiscal Year Ended December 31, 2007
Filed September 29, 2008
File No. 000-12968
Dear Ms. Davis:
This correspondence filing responds to your comment letter of October 1, 2008 on behalf of InMedica Development Corporation (the “Company”). We have set forth each of your comments below followed by the Company’s response:
SEC COMMENT:
Form 10-K/A for Fiscal Year Ended December 31, 2007
Item 9A(T). Controls and Procedures, page 3
| 1. | You state that management is responsible for “establishing and maintaining disclosure control over financial reporting, as defined in the Securities Exchange Act of 1934 Rule 13a-15(e).” As we noted in prior comment number 1, Rule 13a-15(e) defines disclosure controls and procedures. Please note that “disclosure control over financial reporting” is not defined in the Securities Exchange Act of 1934, and confirm that you will refer to “disclosure controls and procedures” in your disclosure pursuant to Item 307 of Regulation S-K in future filings. |
RESPONSE: The Company confirms that it will refer to “disclosure controls and procedures” in its SK Item 307 disclosure in future filings.
SEC COMMENT:
Form 10-Q/A for Fiscal Quarters Ended March 31, 2008 and June 30, 2008
Consolidated Balance Sheet
| 2. | We note your amended Forms 10-Q set forth only an amended balance sheet as of March 31, 2008 and June 30, 2008. Exchange Act Rule 12b-15 requires, among other things, that amendments set forth the complete text of each item as amended. Please further amend your Forms 10-Q/A to present the complete text of Item 1 (i.e. a full set of financial statements and related footnotes). You should also provide updated certifications from your principal executive and principal financial officer. |
RESPONSE: In lieu of the further amendment to these 10Q’s we offer the following reasons why we believe it advisable to allow the amendments to stand as they are:
(1) It is clear in these amendments, as filed, that they affect only the Consolidated Balance sheets.
(2) The amendments made to the balance sheets do not impact any other disclosure in the financial statements and notes.
(3) As filed, it is easier for the reader to identify the changes made when compared with the original filings due to the brevity of the amendment compared to a full amendment and restatement of the entire financial statements and notes.
(4) The Company has in the past followed the practice of fully amending and restating amended items and intends to do so in the future, however, for reasons stated above, it made sense to us to amend only the Consolidated Balance Sheet, in this instance.
As always, we appreciate your advice and direction. Either I, or my partner, Paul Hess, would be happy to respond to any questions you may have.
Very truly yours,
STRONG & HANNI, P.C.
Scott R. Jenkins
Scott R. Jenkins