SAFE TECHNOLOGIES INTERNATIONAL INC.
550 W. Old Country Road, Suite 108
Hicksville, NY 11801
June 12, 2009
Mark P. Shuman, Branch Chief - Legal
Division of Corporation Finance
United States Securities and Exchange Commission
Washington, DC 20549
Re:
Safe Technologies International, Inc. (the “Company”)
Preliminary Information Statement on Schedule 14C
Filed June 3, 2009
File No. 000-17746
Dear Mr. Shuman:
As requested in your comment letter dated June 11, 2009, this letter acknowledges our understanding that:
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the Company is responsible for the adequacy and accuracy of the disclosure in the above filing
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Commission 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
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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.
Sincerely,
/s/ Randi Swatt
Acting Chief Executive Officer
GERALD W. GRITTER PA
Counselor at Law
120 East Palmetto Park Road, Suite 400
Boca Raton, Florida 33432
Telephone (561) 391-8899
Facsimile (561) 892-0492
Gerald W. Gritter
gritterpa@gmail.com
Direct: 561-391-8899
June 12, 2009
Mark P. Shuman, Branch Chief - Legal
Division of Corporation Finance
United States Securities and Exchange Commission
Washington, DC 20549
Re:
Safe Technologies International, Inc. (the “Company”)
Preliminary Information Statement on Schedule 14C
Filed June 3, 2009
File No. 000-17746
Dear Mr. Shuman:
In response to your comment letter dated June 11, 2009, regarding the above filing, the following changes have been made to the Information Statement:
Comment 1:
We have modified the treatment of fractional shares to provide that affected shareholders will have the number of share to which they are entitled rounded up to the nearest whole share. This change appears under “Amendment of Certificate of Incorporation to Effect a Reverse Stock Split - The Reverse Split,” “Amendment of Certificate of Incorporation to Effect a Reverse Stock Split – Fractional Shares,” and in the Certificate of Amendment attached to the Information Statement.
We have also added a statement that the number of shareholders will not be reduced by the reverse split under “Amendment of Certificate of Incorporation to Effect a Reverse Stock Split - The Reverse Split.”
Comment 2:
Under “Compensation,” we have added Valda Reinbergs as a named executive officer, so that all of the Company’s officers are now named. Since neither of the named officers received any compensation for their services as either a director or officer during either of the past two fiscal years, this has been disclosed in narrative form, and the table has been deleted.
We have also provided the requested statement from the Company.
Please contact me if you have any further questions.
Sincerely,
/s/ Gerald W. Gritter
Gerald W. Gritter
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