AcroBoo, Inc.
3000 Bayport Drive, Suite 250
Tampa, Florida 33607
Telephone: (813) 637-6900
March 18, 2011
VIA EDGAR TRANSMISSION AND OVERNIGHT MAIL
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U. S. Securities and Exchange Commission
Division of Corporate Finance
100 F. Street N.E.
Washington, D.C. 20549
Attention: Mr. Christopher Chase, Staff Attorney
Re: AcroBoo, Inc.
Amendment No. 4 to Registration Statement on Form S-1
Filed March 7, 2011
File No.: 333-170477
Dear Mr. Chase:
On behalf of AcroBoo, Inc. (the "Company"), we are hereby responding to the
comment letter, dated March 16, 2011 (the "Comment Letter"), from the Staff
(the "Staff") of the Securities and Exchange Commission (the "Commission")
with respect to the Company's Registration Statement on Form S-1 (File No.
333-170477) (the "Registration Statement"). In response to the Comment
Letter and to update certain information in the Registration Statement, the
Company is filing with the Commission today Amendment No. 5 to the
Registration Statement (the "Amendment"). We are sending you a marked copy
for your review.
For ease of reference, set forth below are the comments of the Staff with
respect to the Registration Statement. The Company's response is set forth
below each comment.
Risk Factors, page 10
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8. Many of our future current and potential competitors..., page 13
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1. Please revise your eighth risk factor on page 13 to clarify why the
software programs from which you expect to generate a small percentage of
your revenues could "have a material adverse effect on [your] operating
performance and financial condition."
Response: We have revised our eighth risk factor on page 13 to clarify the
software programs from which we expect to generate a small percentage of our
revenues could adversely effect on our operating performance and financial
condition based on the percent of business to be generated from our
software programs.
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Description of Business, page 23
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AcroBoo, Inc. Business Plan, page 23
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2. The third through fifth sentences of your Business Plan discussion on
page 23 appear to be inconsistent with your business plan as otherwise
described in your filing. Specifically, we note that the third sentence
suggests that AcroBoo has an operating history, the fourth sentence
inaccurately suggests that you have an existing infrastructure, and the
fifth sentence refers to providing services that are not otherwise
discussed in your filing. Please revise or advise.
Response: We have revised the third through fifth sentences of our Business
Plan discussion to make it consistent with our business plan as described in
our filing.
The Difference Between Jagged Peak and AcroBoo, page 23
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3. Please revise the tense of this discussion on page 23 to remove the
implication that AcroBoo has an operating history.
Response: We have revised the tense of this discussion on page 23 to remove
the implication that AcroBoo has an operating history.
Mr. Chase, we hope our responses satisfactorily address your comments.
Further, on behalf of the company, we acknowledge that:
o the company is responsible for the adequacy and accuracy of the disclosure
in the filing;
o 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
o 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.
Respectfully submitted,
AcroBoo, Inc.
By: /s/ Dan Furlong
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Dan Furlong
Chief Executive Officer
cc: Thomas C. Cook, Esq.
Corporate Counsel
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