VANDERKAM & ASSOCIATES
Attorneys at Law
1301 Travis, Ste. 1200
Houston, TX 77002
Telephone (713) 547-8900
Facsimile (713) 547-8910
June 21, 2006
Maryse Mills-Apenteng
U.S. Securities & Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549
Mail Stop 4561
Re: Integrated Management Information, Inc.
SEC File No. 333-133624
Pre-Effective Amendment No. 1/A
Dear Madam:
This letter is in response to your letter of May 4, 2006 regarding the
afore-referenced registration statement. The responses in this letter correspond
with points and questions raised in your letter of May 4, 2006.
1. We have revised our filing to include the audited financial statements
of Cattlefeeding.com in accordance with Item 310(c) of Regulation S-B.
As to the proforma financial information Please see footnotes 2 to the
audited financial statements of Integrated Management Information, Inc.
for the year-ended December 31, 2005 (pg 45)
2. We have modified our financial statements and have assigned a portion
of the purchase price to intangible assets. This is reflected in the
restated financial statements (see revisions to the balance sheet, pg.
36, statements of operations, pg. 37, footnote 2 pg. 44 and 45 and note
14 restatement, pg. 54).
3. The language "For the initial public offering of the stock of"
Integrated Management Information, Inc. was added to page 1
of the registration statement.
4. We have revised the prospectus cover page as well as the plan of
distribution (pg. 32) to state, "Because there is currently no market
for common stock, the prices at which the selling shareholders will
sell their shares is a fixed price of $.83 until the securities are
quoted on the OTC bulletin board and thereafter at prevailing market
prices or privately negotiated prices.
5. The cover page has been limited to the items identified in Item 501 of
Regulation S-B.
6. We have relocated all of the paragraphs following the table of contents
except for the prospects delivery legend. 7. The paragraph that relates
to the summary section has been included as an introductory paragraph
under the prospectus
summary heading. (Page 4)
8. The title "Selling Shareholders" has been added for the selling
shareholders section.
9. We have added by way of footnotes 2 and 5 to the selling shareholders
section, a description of any material relationship the selling
security holders have had with Integrated Management Information or its
predecessors or affiliates within the past three years (page 31). We
have also provided footnote disclosure to the table identifying the
founding members of the board of directors. (Footnotes 2, page 31)
10. We have identified the underwriters in a footnote to the selling
shareholder table. (Note 4, page 31) These shares were in fact issued
in connection with a past underwriting as compensation and not for
investment purposes.
11. We have identified the natural person or persons who have voting or
investment control over each of the entities listed in the selling
shareholder r table. (Note 3, page 31)
12. There are two persons listed in the selling shareholders table who are
affiliates of a broker but not a dealer, namely Westrock Security, Inc.
These persons are Michael Baker and Deborah A. Ziwot. As disclosed in
footnote 4, these shares were allocated to them directly from the
brokerage firm at the time these shares were issued to the brokerage
firm for compensation. The two individuals are members of the firm.
Neither these individuals or the brokerage firm had any agreement
understanding, directly or indirectly, with any person to distribute
these securities.
13. The undertaking section has been modified to include the recent update.
(Page 75)
14. The signature page has been modified to disclose Mr. Mark McGregor not
only as the Chief Financial Officer of the company but as the Principal
Accounting Officer also. (Page 76)
15. The signature page has been modified and Mr. Mr. McGregor is now
signing both in his capacity as Chief Financial Officer, Principal
Accounting Officer and in his own capacity. (Page 76)
Please contact the undersigned directly should you have any further comments or
need any further information.
Sincerely,
VANDERKAM & ASSOCIATES
/s/ Hank Vanderkam
Hank Vanderkam
HV/avw