ISA INTERNATIONALE INC.
2564 RICE STREET
ST. PAUL, MN 55113
SEC File No. 1-16423
May 16, 2011
U.S. Securities and Exchange Commission
Division of Corporation Finance
Washington, DC 20549
Attn: Mr. Andrew D. Mew
Accounting Branch Chief
Dear Mr. Mew:
We are responding to your letter dated April 27, 2011 concerning our
correspondence filed on April 6, 2011. This was a response to your original
letter dated March 2, 2011 with comments and questions about our Form 10-K
submission for our fiscal year ended 09/30/2010. We are requesting an
additional 10 business days from the due date of May 11, 2011 to prepare and
submit our response. The Company and its Auditors need additional time to
prepare and approve a revised submission. This request was discussed and
approved today by telephone with Mr. Milwood Hobbs, Staff Accountant with the
SEC. The Company will be submitting a revised Form 10-K/A for the
registrant and our letter correspondence responding to all of the points in
your inquiry letter dated April 27, 2011 on or before May 25, 2011. The
Registrant, ISA International Inc., is referred to in this letter as the
"Company" or "ISAT".
Acknowledgements:
The registrant hereby acknowledges that:
1. the Company is responsible for the adequacy and accuracy of the disclosure
in our filings;
2. staff comments or changes to disclosure reported to the SEC in response to
staff comments do not foreclose the SEC 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.
We are attempting to fully comply with the reporting requirements of the SEC
and respectfully ask for your agreement with our conclusions in this
correspondence. Please contact me at 651-489-6941 or by fax at 651-484-9870
if you have additional comments or questions.
Sincerely,
/s/Bernard L. Brodkorb
President, CEO, and CFO
ISA Internationale Inc.