Freight Management Corp.
Suite 200
8275 Eastern Ave
Las Vegas, NV, 89123
August 21, 2009
Mr. David R. Humphrey
Branch Chief
Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 3561
Washington D.C. 20549
Re: Freight Management Corp.
Form 10-K for the year ended December 31, 2008
File No. 000-53127
Dear Sir:
We are writing in response to your comment letter dated August 4, 2009, in
connection with the above-referenced filing
Item 9A. Controls and Procedures
1. Please revise this section to include not only your assessment of Internal
Control over Financial Reporting, but also your assessment of Disclosure
Controls and Procedures, as required by Item 307 of Regulation S-K.
* We have revised this section to include our assessment of Disclosure
Controls and Procedures.
Report of Independent Registered Public Accounting Firm, page F-2
2. Please file an amended Form 10-K to include an accounting report as of and
for the period ended December 31, 2007. The report currently included does
not reference such date.
* Our 10-K/A1 includes an accounting report issued by Seale and Beers
CPA's as of and for the period ended December 31, 2007.
Please note that Seale and Beers replaced Moore and Associates as our auditor
due to the retirement of Moore. We filed an 8-k regarding the replacement on
August 6, 2009.
Note 2 -- Summary of Significant Accounting Practices
Website Costs, page F-8
3. Please tell us how your treatment of website costs is in accordance with
EITF 00-2. Include in your response a break down of the particular
components of the $4,000 gross balance and provide us with detailed support
for your conclusion that these costs should not have been expensed as
incurred.
* We have revised Note 2 "Website Costs" to discuss the treatment of our
website costs in accordance with EITF 00-2.
Our capitalized website costs of $4,000 consist of the following paid to third
party developers:
* Domain name registration - $ 300
* Design of website graphics, page design and layout,
and installation of the website 1,200
* User interface for name registration, password
generation for website use, and website user
query capture and retrieval interface (for
future use with our future online freight
logistics query system) 2,500
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$4,000
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We reviewed EITF 00-2 and SOP 98-1 previously when these costs were incurred and
believe that capitalization of these costs is the appropriate treatment.
Certifications
4. Your certifications should be expanded to also address internal control
over financial reporting. Refer to Item 4 of the certification and to
section (b) thereunder for guidance.
* Exhibit 31.1 and 31.2 certifications have been expanded to address
internal control over financial reporting.
Please also note that we have added a detailed "Explanatory Note" immediately
after the Table of Contents in our 10-K/A1 which provides a detailed explanation
of the above noted changes for our readers.
We also acknowledge that:
1. the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
2. staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission 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.
Sincerely;
/s/ Gerald Lewis
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Gerald Lewis
Principal Accounting and Financial Officer