CUTLER LAW GROUP
Attorneys at Law M. Richard Cutler, Esq.*
9814 Crystal Blvd M Gregory Cutler, Esq.**
Baytown, Texas 77521
(281) 918-0040 Tel (800) 836-0714 Fax *Admitted in California & Texas
www.cutlerlaw.com **Admitted in Florida
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September 30, 2009
Jenn Do, Division of Corporate Finance
Terrence O'Brien, Branch Chief
Tracey Houser, Division of Corporate Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-4561
RE: EXTENSIONS, INC.
FORM 10-K/A FOR THE FISCAL YEAR ENDED DECEMBER 31, 2008
FILED APRIL 15, 2009, MAY 21, 2009 AND JUNE 18, 2009
FORM 10-Q/A FOR THE QUARTER ENDED MARCH 31, 2009
FILED MAY 18, 2009 AND JUNE 18, 2009
FILE NO. 0-26493
Gentlemen and Ladies:
This letter accompanies Amendment No. 3 to the Annual Report on Form 10-K
and Amendment No. 2 to the Quarterly Report on Form 10-Q filed by Extensions,
Inc. (the "Company") on September 30, 2009. We are in receipt of your
correspondence dated June 30, 2009, and addressed to BB Tuley, Chief Financial
Officer of the Company. This letter includes responsive comments to your
letter. We have attached to this correspondence a pdf copy of the filings
marked to show changes from the original.
The responses contained herein correspond in Part and Number to the
comments in your letter of June 30, 2009. The page numbers reflect the page
numbers in the marked pdf copy of the Amended Form 10-K and Amended Form 10-Q
attached hereto.
Form 10-K/A No. 2 for the Fiscal Year Ended December 31, 2008
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General
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1. Please ensure that if you file your 1934 Exchange Act reports on EDGAR
using two different formats that the content of the document for both
formats is exactly the same.
Please be advised that is our standard practice. If there was a difference
between the text/ASCII and PDF versions of the filings that was not intentional.
In reviewing the filings, we noted that the text/ASCII version of Amendment 1 to
Form 10-Q for the Quarter Ended March 31, 2009 did
not match the PDF version at one place in the Controls and Procedures section.
This was an EDGAR formatting error, and is responsive to comment 3 below.
We have reviewed the ASCII and PDF versions of Amendment 2 of Form 10-K for
2008, as well as those of the current filings, line by line to ensure that the
versions match exactly.
Item 9A. Controls and Procedures, page 41
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Management's Report on Internal Control over Financial Reportings, page 41
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2. We have read your response to comment 3 and the revised disclosure in your
amended filing. We note that you continue to provide your conclusion
regarding the effectiveness of your internal control over financial
reporting as of December 31, 2007. Please amend your filing accordingly.
We have corrected this error in both the text/ASCII version and the PDF version
of the filing.
Form 10-Q/A No. 2 for the Fiscal Quarter Ended March 31, 2009
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Item 4. Controls and Procedures, page 9
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Evaluation of Disclosure Controls and Procedures, page 9
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3. We note that you continue to disclosure your conclusion regarding the
effectiveness of your disclosure controls and procedures as of December 31,
2007. As previously requested, please amend your first quarter of fiscal
year 2009 Form 10-Q to revise your disclosure to state your conclusion
regarding the effectiveness as of March 31, 2009. Refer to Item 307 of
Regulation S-K for guidance.
We have corrected this error in the text/ASCII version of the filing and ensured
that the error was not present in the PDF version.
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