Yacht Finders, Inc.
2308-C Kettner Blvd.
San Diego, CA 92101
Telephone (619) 232-1001
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June 22, 2005
Ms. Janice McGuirk
U.S. Securities and Exchange Commission
450 Fifth Street N.W.
Mail Stop 0511
Washington D.C. 20549
Re: File No. 333-121863
Registration Statement on Form SB-2
Filed January 6, 2005
Dear Ms. McGuirk,
We have received your letter dated February 9, 2005, and submit the following
cover letter keyed to the changes in our amended registration statement.
Prospectus Cover Page
1. We have deleted the duplicate risk language.
Prospectus Summary
2. We have expanded the summary to include a brief outline of our business.
3. We have revised the third paragraph to state we are in development stage.
Risk Factors
4. We have removed the word "known".
5. We have expanded the first risk factor to include "and will cease any
activity; therefore you could lose your entire investment".
6. We have added a risk factor that addresses Mr. Greenwood's lack of
experience in the yachting industry.
7. We have added a risk factor that addresses the potential adverse impact on
the primary offering should the shareholders sell their shares at less than
$0.50.
The Current Officer, Geoffrey Greenwood, the Sole Officer
8. We have added a discussion of the potential conflict of interest and a
description of Mr. Greenwood's other business activities under the
"Directors, Executive Officers, Promoters and Control Persons" section.
9. We have revised the narrative to disclose Mr. Greenwood will receive a
reduced salary in the event the full funding is not received.
Use of Proceeds
10. Management has determined the amount of funding we would require to
implement the minimum form of our business plan would be 30% and we have
disclosed this in the filing.
11. We have clarified to note the salaries are management salaries.
Determination of Offering Price
12. As stated in the section, the price was arbitrarily set based upon their
collective judgment as to a price per share they were willing to accept.
13. We have revised the disclosure to correctly state the offering price for
the shares being sold by the company vs. the shareholders.
Plan of Distribution
14. We have divided the section into two sub-sections addressing each offering.
15. We have added the statement to the "offering by the company" regarding the
use of an underwriter and the post-effective amendment filing requirements.
16. We have moved this paragraph to the beginning of the section and addressed
the directors' funding.
Directors, Executive Officers....
Work History
17. We have substantially revised the resume section to delete the promotional
tone and just present the facts.
18. We have described the business activities of each entity.
19. We have clarified the amount of capital that we are referring to, including
the time frame for the receipt of that capital.
Description of Securities
20. We have divided the section between common stock and preferred stock.
Legal Matters
21. We have removed the term "independent".
Organization in the Last Five Years
22. The incorporator spelled the name wrong by mistake and then corrected it.
The company was incorporated by its resident agent and had no operations or
business plan from the time of its original formation in August 2000 until
Mr. Greenwood was appointed as director in 2003 and the company name
changed to Yacht Finders to better fit with our business. We have disclosed
that the company had no operations from inception until April 2003.
23. There were no promoters of Sneeoosh Corporation and nothing of any value
(including money, property, contracts, options or rights of any kind) were
received by any person from the company until Mr. Greenwood received his
shares in April 2003 as disclosed.
Description of Business
Form and Year of Organization
24. We have added a description of the yacht brokerage industry to this
section.
Principal Products or Services...
25. We have disclosed the nature and extent of features of our web site and the
number and nature of users at the present time.
26. We have disclosed whether or not management has experience in performing
the functions or services as contemplated.
27. We have added the source of the comparative services' charges mentioned.
28. We have clarified the pricing plans, providing descriptions of specific
services.
29. We have disclosed there is no assurance the company will raise the full
amount of the offering.
30. We have removed the duplicative disclosure from this section.
Competition and Competitive Position
31. We have disclosed that all claims to the number of members are from each
company's respective website.
32. We have added an explanation as to how we believe we will be able to offer
a better solution than our competitors.
Reports to Securities Holders
33. We have revised to read "We will provide an annual report...".
Plan of Operation
34. We have disclosed that currently there are no formal commitments or
arrangements with our director to advance or loan funds to Yacht Finders
for operating expenses. There are also no terms regarding repayment of any
loan or capital contribution.
35. We have included the disclosure regarding Mr. Greenwood's informal
agreement to advance the company funds to complete the registration process
in the event we experience a shortfall of funds.
36. We have disclosed the use of proceeds to date and the potential use of the
remaining proceeds in the future. 37. We have expanded the disclosure on
our activities. 38. We have expanded the disclosure to include the extent
of activities in both a 30% and 60% funding scenario.
Executive Compensation
39. We have expanded the table to include 2004. 40. We have removed reference
to a "board of directors".
Balance Sheets
Website Development Costs, F-3
41. The new audit as of December 31, 2004 and March 31, 2005 addresses the
website development costs as an expense.
General
42. We have updated the prospectus to the latest practicable date. 43. We have
forwarded a marked copy to you via US Mail. 44. We have included current
consents and have also included financials through 3/31/05.
Sincerely,
/s/ Geoffrey Greenwood
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Geoffrey Greenwood
President & Director