March 18, 2015
Mr. Patrick Gilmore
Accounting Branch Chief
United States Securities and Exchange Commission
Washington, D.C. 20549
Re: Response to comment letter dated March 6, 2015
Dear Mr. Gilmore:
We are in receipt of your comment letter dated March 6, 2015 and have the following responses:
Form 10-K for the Year Ended June 30, 2014
Item 9.A Controls and Procedures Internal Control Over Financial Reporting, page 7
| 1. | Please amend your filing to include a statement identifying the framework used to evaluate the effectiveness of your internal control over financial reporting. Refer to item 308(a)(2) of Regulation S-K. |
We respond:
We have filed an amendment to our Annual Report on Form 10-K to include a statement identifying the framework used to evaluate the effectiveness of our internal control over financial reporting.
Exhibits 31.1 and 31.2
| 2. | Please revise your certification to remove the certifying officer’s tile. Refer to Item 601(31)(i) of Regulation S-K. Similar concerns apply to Exhibit 31.2. |
We respond:
Our exhibits 31.1 and 31.2 have been updated to remove the certifying officers’ titles.
We acknowledge:
| ● | 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. |
Sincerely,
/s/ Andrew Ecclestone |
| /s/ Kimberly Conley |
Andrew Ecclestone Chief Executive Officer and Director |
| Kimberly Conley Principal Financial Officer |
