SYSVIEW TECHNOLOGY
WILLIAM M. HAWKINS
CHIEF OPERATING OFFICER
ACTING CHIEF FINANCIAL OFFICER
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July 25, 2006
VIA EDGAR--CORRESP
Stephen Krikorian
Accounting Branch Chief
Division of Corporate Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: SYSCAN IMAGING, INC.
FORM 10-KSB FOR FISCAL YEAR ENDED DECEMBER 31, 2005
FORM 10-QSB FOR FISCAL QUARTER ENDED MARCH 31, 2006
FILE NO. 000-25839
Dear Mr. Krikorian:
We are submitting this correspondence via the EDGAR system in response to a
comment letter issued by the Securities and Exchange Commission ("SEC") on July
18, 2006. Please note that the Company's corporate name has changed from Syscan
Imaging, Inc. to Sysview Technology, Inc. effective June 27, 2006. In connection
with that comment letter, we will amend such filings as discussed below. We look
forward to fully cooperating with you in these respects. And we welcome any
comments and/or guidance in areas where you think we should further revise our
documents.
In addition, the comment letter sought certain declarations from the company. As
such, we hereby declare and acknowledge the following:
o the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
o staff comments or changes to disclosure in response to staff comments
do not foreclose the SEC from taking any action with respect to the
filing; and
o the company may not assert staff comments as a defense in any
proceeding initiated by the SEC or any person under the federal
securities laws of the United States.
The numbered responses below correspond to the numbered comments in the SEC's
letter.
FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2005
CONSOLIDATED STATEMENT OF OPERATIONS, PAGE F-3
1. Response - While Syscan and our independent accountants are confident that
recognizing the entire intrinsic value of the 3.7 million options as
compensation costs on the grant date is more indicative of the underlying
economic transaction as compared to recognizing compensation costs over the
period in which the requisite service is performed, we will revise the financial
statements contained in our 2005 Form 10-KSB and March 31, 2006 Form 10-QSB as
requested.
2. Response -
o Upon further review and consideration, the statement on page 35,
"Other income in 2004 primarily consisted of the sale of certain
inventory items previously considered not-sellable" was removed as the
amount is immaterial and it does not help a reader of our financial
statements understand our business.
1772 Technology Dr., San Jose, CA 95110
Tel: 408-213-3707 Fax: 408-490-2801
SYSVIEW TECHNOLOGY
WILLIAM M. HAWKINS
CHIEF OPERATING OFFICER
ACTING CHIEF FINANCIAL OFFICER
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FORM 10-QSB FOR THE QUARTERLY PERIOD ENDED MARCH 31, 2006
NOTES TO CONDENSED CONSOLIDATED FINANCIAL STATEMENTS
NOTE 11 - RESTATEMENT OF MARCH 31, 2005 INTERIM RESULTS FOR CORRECTION OF AN
ERROR, PAGE 13
3. Response - In response to Comment 3, we intend to file a Form 8-K with the
SEC pursuant to Item 4.02 on July 26, 2006.
4. Response - The management of Syscan believes the company has complied with
all its reporting obligations under Form 8-K, except for the isolated incident
with respect to restating our financial statements to correct the accounting
treatment of our preferred stock. Management also believes this was an isolated
anomaly under extenuating circumstances (the transaction was a onetime equity
transaction subject to relatively new and extremely complex accounting
guidance). As this single incident is indicative of the complex transaction, not
of our disclosure controls and procedures over financial reporting, we have been
able to conclude that our disclosure controls and procedures are effective as of
the end of each reporting period.
* * * *
If you have any further questions, please feel free to contact me directly at
anytime at 408-217-3707.
Very truly yours,
/s/ William Hawkins
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William (Bill) Hawkins, CFO
Sysview Technology, Inc.
cc: Jody R. Samuels, Esq.
1772 Technology Dr., San Jose, CA 95110
Tel: 408-213-3707 Fax: 408-490-2801