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September 7, 2010
United States Securities and Exchange Commission
Division of corporation Finance
100 F Street, N.E.,
Washington D.C. 20549
Attention: Melissa Walsh
Dear Ms. Walsh:
Re: Correspondence dated August 3, 2010
Further to your letter of August 3, 2010, please see our replies to your queries below:
A Form 20-F/A was filed in response to this letter on August 20, 2010.
Form 20-F for the Fiscal Year Ended December 31, 2009:
1.
Cover Page
Fiscal Year corrected on Cover Page
2.
Item 16.
Audit Committee, Code of Ethics, Accountant Fees, Page 24
Item 16F is now included providing disclosures
3.
Item 17.
Financial Statements, Page 25
Dates are now corrected
SEC REPLY
September 7, 2010
Page 2 of 2
A Form 6-K/A will be filed in response to this letter on September 7, 2010.
Form 6-K filed July 16, 2010
1.
Interim Statement for the Six Months Ended June 30, 2010
Corrected and Amended
The Company acknowledges the following:
1.
The Company is responsible for the adequacy and accuracy of the disclosure in the filing;
2.
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
3.
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.
If you have any further queries, please do not hesitate to contact us.
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Deborah Fortescue-Merrin
President and C.E.O.
HEAD OFFICE:
Canon’s Court, 22 Victoria Street, Hamilton HM12, Bermuda
Phone: 441-295-2244 Fax: 441-292-8666
NORTH AMERICAN CONTACT:
PO Box 280, 590 Willies Way, Bowen Island, BC, Canada V0N 1G0
Phone: 604-947-2554 Fax: 604-947-0294