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Lehman & Eilen LLP
20283 State Road 7, Suite 300
Boca Raton, FL 33498
Tel. (561) 237-0804
September 14, 2009
VIA EDGAR AND
OVERNIGHT MAIL
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United States Securities
and Exchange Commission
100 F Street, NE
Mail Stop 4561
Washington, D.C. 20549
Attention: Maryse Mills-Apenteng
Special Counsel
RE: SEAMLESS CORPORATION
PRELIMINARY REVISED INFORMATION STATEMENT ON SCHEDULE 14C
FILED AUGUST 13, 2009
FILE NO. 000-20259
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Dear Ms. Apenteng:
Thank you for your August 20, 2009 letter regarding Seamless Corporation
(the "Company"). Enclosed is Amendment No. 2 to Schedule 14C, which has been
marked to show changes from our prior submission. The changes in the revised
Schedule 14C reflect the staff's comments to the previously submitted material.
Also, in order to assist you in your review of the Company's Schedule 14C, we
hereby submit a letter responding to the comments. For your convenience, we have
set forth below the staff's numbered comments in their entirety followed by our
responses thereto.
General
1. Please file marked copies of the new charter documents adopted by
the board in connection with the change in domicile from Nevada to
Florida. The charter documents should be marked to indicate the
differences between your Nevada charter documents and the new
charter documents and should be filed as appendices to your revised
information statement. In addition please provide us with a copy of
your current Nevada charter documents with your response letter. We
note that the charter documents incorporated by reference in your
most recent Form 10-K refer to business other than Seamless
Corporation. Consider therefore filing a copy of your current
articles of incorporation and bylaws as well.
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United States Securities
and Exchange Commission
September 14, 2009
Page 2
Response: Complied with. Enclosed are marked copies of the new
charter documents. Please note we have also filed our restated
articles of incorporation and bylaws along with the revised
information statement. See exhibits D and E.
Item 1. Information Statement, page 2
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2. You state "[t]he name change will reflect the Companies the [sic]
marketing and selling of Gadgets and Technology." Please revise here
and elsewhere as applicable, to clarify the reasons for the name
change and to indicate specifically whether the name change is due
to a change in your business activities. Any changes to your
business activities in connection with the reincorporation must be
described.
Response: Please note that although Seamless Corporation will not
change its name, the Florida corporation in which the Seamless
shareholders will own stock will be named GDT TEK, Inc. We have
revised our filing to clarify the reasons for naming the Florida
corporation, GDT TEK, Inc.
Process to Redomicile, page 3
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3. We note your response to prior comment 2 of our letter dated August
6, 2009 and we reissue that comment. A cursory review of Nevada and
Florida statutes reveals material differences with respect to
shareholder rights regarding, amount other matters, appraisal
rights, the sale of assets, the right to call a meeting, to inspect
records and to remove directors. As previously indicated you must
provide a comparison of the material provisions of each state's
laws, highlighting the material differences between the corporate
law provisions of Nevada and Florida as they relate to the rights of
shareholders. This information should be presented in a side-by-side
comparison of each state's laws. In addition, as previously
requested, you must also include in the information statement a
similar side-by-side comparison of any material changes to your
articles of incorporation and bylaws that will result from the
reincorporation. Your statements to effect that the change in
domicile will have a "minimal" effect on existing shareholders and
that the rights of shareholders" are not expected to change in any
significant fashion: do not adequately address the disclosure
requirement. Further, your revised filing should avoid general
discussion of the laws governing corporations such as your
references to the "Encyclopedia of Everyday Law" and the Model
Business Corporation Act. Please revise your disclosure accordingly.
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United States Securities
and Exchange Commission
September 14, 2009
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Response: Complied with. We have added a side-by-side comparison of
the material changes from the Nevada corporation to a Florida
corporation to our filing. We have also disclosed the changes in our
articles of incorporation and bylaws.
Please feel free to call me at (561) 237-0804 if you have any questions.
Thank you.
Sincerely,
/s/ Hank Gracin
Hank Gracin
cc: Seamless Corporation