CORRESPONDENCE
Request for Acceleration; The Company/Registrant’s Acknowledgments; and Memorandum of Responses.
Bluegate Corporation
701 North Post Oak Road, Suite 600
Houston, Texas 77024
From the desk of:
Charles E. Leibold
Chief Financial Officer of
Bluegate Corporation
To: | Philip L. Rothenberg, Staff Attorney, and Karen J. Garnett, Assistant Director | |
Mail Stop 4561 | ||
Division of Corporate Finance, Securities and Exchange Commission | ||
Washington, D.C. 20549-7010 |
With copy to: | Joel Seidner, Esq. | |
880 Tully Road #50, Houston, Texas 77079 | ||
voice: (281) 493-1311 fax: (281) 667-3292 |
August 24, 2007
Ref: | Bluegate Corporation (the “Company” and the “Registrant”) | |
Form SB-2 | ||
SEC File number 333-145492 | ||
Filing date: August 16, 2007 |
Dear Philip L. Rothenberg and Karen J. Garnett:
Request for Acceleration of Effectiveness of Form SB-2;
the Company/Registrant’s Acknowledgments; and
Memorandum of Responses.
My name is Charles E. Leibold. I am the Chief Financial Officer of Bluegate Corporation (the “Registrant”). I am the Registrant’s authorized signatory for this Request for Acceleration; the Company/Registrant’s Acknowledgments; and Memorandum of Responses.
Request for Acceleration of Effectiveness of Form SB-2. The Registrant requests that the effectiveness of above referenced Form SB-2 be accelerated to be August 30, 2007 at 9 A. M. EST.
The Company/Registrant’s Acknowledgments. The Company/Registrant acknowledges that:
(a) | Should the Commission or the staff, acting pursuant to delegated authority, declare the Filing effective, it does not foreclose the Commission from taking any action with respect to the Filing; |
(b) | The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Filing effective, does not relieve the Company/Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Filing; and |
(c) | The Company/Registrant may not assert the staff comments or the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Memorandum of Responses.
Response to Staff comment number 1 about filings using an outdated form of certification for exhibits 31.1 and 31.2:
On August 24, 2007, the registrant filed one amended Form 10-KSB and two amended Forms 10-QSB with the correct certifications for exhibits 31.1 and 31.2 as Form 10-KSB/A for the fiscal year ended 12-31-06; and as two Forms 10-QSB/A for the fiscal quarters ended 3-31-07 and 6-30-07.
Thank you.
/s/ Charles E. Leibold | ||
Charles E. Leibold | ||
Chief Financial Officer of Bluegate Corporation |