clickNsettle.com, Inc.
990 Stewart Avenue, 1st Floor
Garden City, NY 11530
January 24, 2007
Filed Via Edgar
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United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington D.C. 20549
Attention: Ms. Yolanda Crittendon
Staff Accountant
Mail Stop 4561
RE: clickNsettle.com, Inc.
Form 10-KSB for Fiscal Year Ended June 30, 2006
Form 10-QSB for Fiscal Quarter Ended September 30, 2006
File No. 000-21419
Dear Ms. Crittendon:
This letter sets forth the response of clickNsettle.com, Inc. (the "Company") to
the comment received from the Staff of the Securities and Exchange Commission by
letter dated January 18, 2007.
Item 8A - Controls and Procedures
1. We noted that you evaluated disclosure controls and procedures
within 90 days prior to the filing date for the year ended June 30,
2006 and the period ended September 30, 2006. Advise us on how you
comply with the requirements in Item 307 of Regulation S-B to
conclude on the effectiveness as of the end of the period covered by
the report, or revise accordingly.
Response to Above Comment:
1. We did in fact evaluate our disclosure controls and procedures as of
the end of both periods. That is, our evaluation was performed as of
June 30, 2006 and as of September 30, 2006, respectively. As such,
we were in full compliance with the requirements in Item 307 of
Regulation S-B. Going forward, effective with our filing of Form
10-QSB for the quarterly period ended December 31, 2006, we will
ensure that our response to this item, Controls and Procedures, will
be more specific. That is, we anticipate our response to be as
follows:
CONTROLS AND PROCEDURES
Our disclosure controls and procedures are designed to ensure that
material information relating to the Company are made known to our Chief
Executive Officer ("CEO"), Chief Financial Officer ("CFO") and others in the
Company involved in the preparation of this quarterly report, by others within
the Company. Our CEO and CFO have reviewed our disclosure controls and
procedures as of December 31, 2006 and have concluded that they are effective.
There have been no significant changes in our internal controls or other factors
that could significantly affect our internal controls subsequent to December 31,
2006, the last date they were reviewed by our CEO and CFO.
The Company hereby acknowledges the following:
o the Company is responsible for the adequacy and accuracy of
the disclosure in the Form 10-KSB and the Form 10-QSB filings;
o staff comments or changes to disclosures in response to staff
comments do not foreclose the Commission from taking any
action with respect to the filings; and
o 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 questions or comments concerning the above, please do not
hesitate to contact me at 516-941-3222. My direct fax number is 516-213-7600.
Also, please update your records to use my direct fax number as the Company's
fax going forward.
Very truly yours,
/s/ Patricia Giuliani-Rheaume
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Patricia Giuliani-Rheaume
Vice President, Chief Financial Officer & Treasurer
cc: Robert S. Matlin, Kirkpatrick & Lockhart Preston Gates Ellis LLP