CUTLER LAW GROUP M. Richard Cutler, Esq.*
Attorneys at Law M Gregory Cutler, Esq.**
www.cutlerlaw.com *Admitted in California & Texas
**Admitted in Florida
October 17, 2008
Chris White, Branch Chief
Gary Newberry
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-7010
RE: HST GLOBAL, INC. (F.K.A. NT HOLDING CORP)
AMENDMENT NO. 2 TO FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2007
FILED OCTOBER 17, 2008
FILE NO. 0-15303
Gentlemen and Ladies:
This letter accompanies Amendment No. 2 to the Annual Report on Form 10-K
for the Year Ended December 31, 2007 filed by HST Global, Inc. (f.k.a. NT
Holding Corp) (the "Company") on October 17, 2008.
We are in receipt of your correspondence dated October 8, 2008, and
addressed to Wesley Tate, Chief Financial Officer of the Company. This letter
includes responsive comments to your letter. As a courtesy, we have sent to
your office copies of the filing marked to show changes from the original
filing.
The responses contained herein correspond in number and part to the
comments in your letter of October 8, 2008. The page numbers reflect the page
numbers in the courtesy copies of the Amended Form 10 sent to your office.
FORM 10-K/A#1 FILED OCTOBER 6, 2008
1. IN A FULL AMENDED FILING INCLUDING FINANCIAL STATEMENTS, PROVIDE SIGNATURES
OF YOUR CURRENT CHIEF EXECUTIVE AND FINANCIAL OFFICERS. PLEASE NOTE THAT
ALTHOUGH YOU ARE FILING AN AMENDMENT TO A PREVIOUSLY FILED FORM 10-K, THE
AMENDED IS TREATED AS A CURRENT FILING AND THEREFORE MUST BE SIGNED BY YOUR
CURRENT OFFICERS.
We have filed a full amended filing including financial statements, signed by
our current chief executive and financial officers.
2. WE HAVE CONSIDERED YOUR RESPONSE TO OUR PRIOR COMMENT IN OUR LETTER OF JULY
18, 2008. PLEASE PROVIDE REVISED CERTIFICATIONS WORDED EXACTLY AS REQUIRED
UNDER ITEM 601(B)(31) OF REGULATION S-K, SIGNED BY YOUR CURRENT CHIEF
EXECUTIVE AND FINANCIAL OFFICERS. THESE CERTIFCATIONS SHOULD OMIT THE TITLE
OF THE SIGNER IN THE OPENING LINE OF CERTIFICATION. ALSO, THE TOP SHOULD BE
TITLED ONLY "CERTIFICATIONS". PLEASE CONTACT US AT THE NUMBER BELOW IF YOU
HAVE ANY QUESTIONS.
We have amended Exhibits 31.1 and 31.2 accordingly.
3. YOUR AMENDED FILING HAS OMITTED THE CERTIFICATIONS REQUIRED BY SECTION 906
OF THE SARBANES-OXLEY ACT OF 2002, AS DESCRIBED IN ITEM 601(B)(32) OF
REGULATION S-K. PLEASE FURNISH THIS CERTIFICATION AS AN EXHIBIT IN YOUR
AMENDED FILING, SIGNED BY BOTH YOUR CURRENT PRINCIPAL EXECUTIVE AND
ACCOUNTING OFFICERS.
We have included amended Exhibits 32.1 and 32.2 accordingly.
4. SUBMIT YOUR RESPONSE TO THESE COMMENTS AS CORRESPONDENCE ON THE EDGAR
SYSTEM, INCLUDING A STATEMENT FROM THE COMPANY REQUESTED IN OUR LETTER OF
JULY 18, 2008 ACKNOWLEDGING THAT:
- THE COMPANY IS RESPONSIBLE FOR THE ADEQUACY AND ACCURACY OF THE
DISCLOSURE IN THE FILING;
- 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
- 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 regret that our previous correspondence filing on EDGAR was unsuccessful. We
have submitted our response to these comments on the EDGAR system as a
correspondence, and will ensure that it is properly accepted and received by
your office.
ACKNOWLEDGEMENT
The company hereby acknowledges that:
- - the company is responsible for the adequacy and accuracy of the disclosure
in the filing;
- - 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
- - 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.
HST Global, Inc.
By: \s\ Ron Howell
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Ron Howell, CEO
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If you have any further questions or comments, please do not hesitate to
contact us.
Very truly yours,
\s\ M Gregory Cutler
M Gregory Cutler
Cutler Law Group