CUTLER LAW GROUP
Attorneys at Law M. Richard Cutler, Esq.*
3355 West Alabama, Suite 1150 M Gregory Cutler, Esq.**
Houston, Texas 77098
(713) 888-0040 Tel (800) 836-0714 Fax *Admitted in California & Texas
www.cutlerlaw.com **Admitted in Florida
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August 9, 2010
Kei Nakada, Staff Accountant
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-4561
Re: HST Global, Inc
8-K filed June 28, 2010
File No. 000-15303
Ms. Nakada:
This letter accompanies Amendment No. 1 to HST Global, Inc.'s Current
Report on Form 8-K filed August 10, 2010, and originally filed June 28, 2010.
It also references the Company's Amendment No. 1 to its Quarterly Report on Form
10-Q for the Quarter Ended March 31, 2010, which will be filed shortly. We are
in receipt of your letter dated June 30, 2010 regarding the Item 4.02 8-K filed
June 28, 2010 by HST Global, Inc. (the "Company"), and are in the process of
responding to your comments. This letter corresponds in part and number to the
comments of your letter. As a courtesy, a marked copy of both the 8-K Amendment
and the provisional changes to the 10-Q.
1. Please note that you are required to provide your independent account with
a copy of the Item 4.02 disclosure no later than the day that you file the
disclosure with the Commission. Please obtain a letter from your
independent accountant that states whether the independent accountant
agrees with your Item 4.02 disclosures and amend your Form 8-K to file the
letter as an exhibit thereto. Such letter must be filed within two business
days of your receipt, Refer to Item 304(c) of Regulation S-K.
Please be advised that we provided a copy of the Item 4.02 disclosure to Madsen
& Associates one day prior to filing the original Form 8-K. We did not receive
a response from Madsen & Associates until August 6, 2010, as Mr. Madsen was out
of the country until then. The letter from Madsen & Associates has been filed
with the 8-K amendment.
2. Please amend your Item 4.02 disclosure to state how and when you plan to
resolve this non-reliance of your financial statements that were included
in your Form 10-Q for the quarterly period ended March 31,2010. Your
disclosure should state whether and when you plan to amend your From 10-Q
to specifically state that the financial statements were not reviewed and
why they were not reviewed. Your disclosure should also state whether and
when you plan to amend your Form 10-Q to include the reviewed financial
statements. If you do not plan to make these amendments, please tell us why
you do not believe these amendments are necessary.
We have amended our Item 4.02 disclosure to state that on August 6, 2010, our
10-Q was reviewed by Madsen & Associates, and that we have amended our Form 10-Q
to make some minor changes suggested by Madsen & Associates. We will file the
10-Q as soon as the Company's management approves the filing.
3. Please confirm that you will reconsider your disclosure controls and
procedures and internal controls over financial reporting in light of this
non-reliance of your March 31, 2010 financial statements. Please also
confirm thai you will modify your disclosures under Item 4 of your amended
Form 10-Q to reflect this reconsideration accordingly.
We have amended our Form 10-Q to reflect the additional material weakness
regarding the delay in auditor review of our financial statements.
4. Please note that Item 4.02 are required to be furnished within four
business days of determining that your financial statements should no
longer be relied upon. Your failure to meet this deadline may disqualify
you from filing certain 33 Act Forms in the future.
We note this requirement and apologize for the delay.
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The Company and its management hereby acknowledge 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\ Ronald R. Howell
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Ronald R. Howell
President
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Please do not hesitate to contact our office should you have any questions
or concerns on this matter.
Very truly yours,
M Gregory Cutler
Cutler law Group