Item 405 of Regulation S-K is not contained herein, and will not be contained, to the best of registrant's knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K o.

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or a smaller reporting company as defined by Rule 12b-2 of the Exchange Act: smaller reporting company þ.

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act): Yes o     No þ.

The aggregate market value of the registrant's common stock, $0.01 par value, held by non-affiliates (21,201,254 shares) was approximately $59,363,511 based on the average closing bid and asked prices ($2.80) for the common stock on April 7, 2008.

At April 7, 2008, the number of shares outstanding of the registrant's common stock, $0.01 par value (the only class of voting stock), was 28,831,254.

 

 

 

TABLE OF CONTENTS

             
        Page
       

PART I.

       
  Item       1.        Business      
  Item       1A.      Risk Factors      
  Item       1B.      Unresolved Staff Comments      
  Item       2.        Properties      
  Item       3.        Legal Proceedings      
  Item       4.        Submission of Matters to a Vote of Security Holders      

PART II.

       
  Item       5.        Market for Registrant's Common Equity, Related Stockholder Matters, and Issuer Purchases of Equity Securities      
  Item       6.        Selected Financial Data      
 

Item       7.        Management's Discussion and Analysis of Financial Condition and Results of Operations

     
  Item       7A.     Quantitative and Qualitative Disclosures about Market Risk      
  Item       8.        Financial Statements and Supplementary Data      
  Item       9.        Changes in and Disagreements with Accountants on Accounting and Financial Disclosure      
  Item       9A.     Controls and Procedures (Item 9A (T))      
  Item       9B.     Other Information      

PART III.

       
  Item     10.      Directors, Executive Officers and Corporate Governance      
  Item     11.      Executive Compensation      
  Item     12.      Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters      
  Item     13.      Certain Relationships and Related Transactions, and Director Independence      
  Item     14.      Principal Accountant Fees and Services      
  Item     15.      Exhibits and Financial Statement Schedules      
                         Signatures      
     
2

 

 

PART I

 

ITEM 1.

BUSINESS

 

As used herein the terms “Company,” “we,” “our,” and “us” refer to SunVesta, Inc., its predecessors, and its subsidiaries, unless context indicates otherwise.

 

Corporate History

 

The Company was incorporated under the laws of the State of Florida on September 12, 1989, as “Thor Ventures Corp.” On November 26, 2002, the Company’s name was changed to “Jure Holdings, Inc.” as part of a process to restructure the corporation. On April 25, 2003, we acquired OPENLiMiT Holding AG, a Swiss developer of digital signature software and subsequently changed our name to “OPENLiMiT, Inc.” We spun-off OPENLiMiT, Holding AG to our stockholders on September 1, 2005. On August 24, 2007 we changed the Company’s name to “SunVesta, Inc.” and on August 27, 2007 acquired SunVesta Holding AG as a wholly owned subsidiary.

 

SunVesta HoldingAG was incorporated under the laws of Switzerland on December 18, 2001 and is domiciled in Zug, Switzerland. SunVesta HoldingAG operates through its wholly-owned subsidiaries, as follows:

 

 

 

 

SunVesta Holding AG

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SunVesta Projects &

Management AG

Switzerland

100%

 

SunVesta Tourism

Costa Rica Limitada

Costa Rica

100%

 

 

Rich Land Investments

Limitada

Costa Rica

90%

 

SunVesta Turistik

Yatirim ve Ticaret A.S.

Turkey

100%

 

The Company’s principal place of business is located at Seestrasse 97, Oberrieden, Switzerland, CH-8942, and our telephone number is (011) 41-43-388-40-60.

 

The Company’s registered agent is Corpdirect Agents, Inc., located at 515 E. Park Ave., Tallahassee, Florida, 32301.

 

The Company

 

The Company intends to develop high-end luxury hotels and resorts in emerging tourist destinations. These complexes will be composed of a traditional hotel operation combined with villas to be sold within the framework of a fractional private residence club program. Members will have international membership privileges.

 

We will concentrate initially on offering luxury hotel products located in attractive, top-class coastal vacation destinations in countries such as Costa Rica, Vietnam and Turkey that are fast emerging as popular tourist destinations. Building on the anticipated success of our initial offerings, we intend to extend our innovative program of private residence clubs and fractional ownership to traditional tourist destinations in order to attract business, sports, and shopping travelers. Ultimately, we intend to develop at least one

 

 

 

exclusive luxury hotel and resort in the top vacation destination on each continent in addition to at least five world-class locations that will serve as city boutique and mountain resort hotels.

Our initial real estate development is to be constructed on 8.5 hectares of prime land located in Guanacaste, Costa Rica, that includes a concession to build an exclusive resort & spa hotel with a luxury private residence club. The construction of the $190 million SunVesta Papagayo Princess Resort is expected to start in 2009 and to be completed in late 2010 or early 2011.

 

Business Considerations

 

Country specific conditions are taken into account when fractional ownership properties are considered for development. The main variable factor is the definition of the right of use that can range from temporary renting or leasing assignments to ownership-like securitization, from built-in taking-back and buy-back options or refund terms including capital reimbursement to indefinite ownership transfers.

 

We intend to direct our investment priority towards emerging market countries with beneficial land acquisition costs and the foreseeable development of tourism, in countries such as Costa Rica, Vietnam and Turkey. More basic considerations as to where to develop properties include the stability of local political conditions, geologically useful cultivability, and types of destinations that attract a five-star clientele. Each potential investment is first compared against a validation checklist and then, if warranted, subjected to a substantial due diligence process. Since location is key to the success of any tourist based luxury real estate project each development is carefully considered during the eligibility process. We also intend to consider projects in fully developed tourist areas. Promising development opportunities often arise from luxury real estate developments driven into foreclosure or sold at auction.

 

Distribution Channels

 

The Company intends to utilize traditional and existing third party distribution channels. We are in the process of identifying experienced business-partners to achieve best sales results. The selection of third party contractors will be made according to geographical and demographical requirements. For example: we will focus on engaging contract sales organizations to market the SunVesta Papagayo Princess Resort in Costa Rica from the United States, Canada, Central America, and South America.

 

Other prospective distribution channels are:

 

Large and strong real estate brokers

Travel agencies

Asset managers and insurance brokers

Specialized brokers for residence clubs, destination clubs and high-end fractional interests

Hotel management companies

Direct Sales at the resort through SunVesta and/or the hotel management company

Fractional Interest Market - Key Findings

 

Industry Size (from Fractional Interest Report by NorthCourse Leisure Real Estate Solutions)

 

As of March 2005, some 170 fractional interest resorts that had begun sales prior to December 31, 2004 have been identified. The majority of fractional resorts are located in the U.S. (142), followed by Canada (16), Mexico (5), the Caribbean (4) and three in other locations. These counts include only significant offerings, and not properties with only a handful of units. Also excluded in this count are “destination clubs”, as defined in a following section.

 

 

 

 

Fractional interest resorts may be arbitrarily classified by aggregate retail sales price per unit, including 93 resorts in the “traditional fractional interest” tier at less than $500 per square foot, 40 in the “high-end fractional” (HFI’s) tier at $500 to $999 per square foot, and 37 “Private Residence Clubs” (PRC’s) with $1,000 or higher per square foot. HFI’s and PRC’s have shown particularly strong growth in recent years. Among the 72 identified fractional resorts in active sales during 2004, 16 were traditional fractional interests, 27 were HFI’s, and 29 were PRC’s.

 

Fractional interest resorts in active sales during 2004 offered approximately 2,195 units. Half of these units were offered in PRC’s resorts (52.2%).

 

Fractional interest sales totaled approximately $1,075 million worldwide during 2004. Included in the total are $625 million in developer sales volume of fractional interests and $450 million in sales volume of destination clubs. This represents a substantial increase to 2003, when fractional interest developers sold an estimated $373 million in new fractional interests and destination clubs sold $140 million in memberships. A continuous market growth of over 30% per year (average) is expected for the next 10 years.

 

In addition to the above $1,075 million, $31.5 million of resales and $436.7 million of presales were generated in the 2004 for a grand total of over $1.5 billion.

 

Product (from Fractional Interest Report by NorthCourse Leisure Real Estate Solutions)

 

Fractional interest resorts exist in four primary types of destinations – ski (52%), golf (23%), beach (20%) and urban (3%).

 

Fractional interest share sizes range from 1/25 (two weeks of annual ownership) to 1/4 (13 weeks of annual ownership). Among other resorts actively selling in 2004, the average size of traditional fractionals was 1/5, which equates to 9 or 10 weeks of annual ownership. HFI and PRC resorts tended towards smaller fractions, averaging 1/7 and 1/8 shares respectively (6 to 8 weeks of annual ownership).

 

The average price of a fractional interest was $221,600 in 2004, up from an average of $207,800 in 2003. Prices at PRC resorts averaged $247,000 per fraction, HFI’s $165,000 per fraction and traditional fractional interests $99,200 per fraction. Prices are expected to increase at the same rate for the coming years.

 

Maintenance fees average $285 per week of annual use for traditional fractional interests, $830 for HFI’s and $1,430 for PRC’s. Fees vary significantly by unit size, resort features, and other characteristics.

 

The most common reservation methods are rotating priority systems (owners select their choice of weeks based on rotating priority) and rotating calendar systems (weeks assigned each owner change on a pre-determined basis).

 

One bedroom units are most common at traditional fractional resorts, while two-bedroom units are most common at HFI and PRC resorts. Among other resorts selling in 2004, traditional fractional units averaged 1,670 square feet, HFI’s 2,500 square feet, and PRC’s 1,740 square feet. PRC units tend to be smaller than HFI units due to locations featuring exceptionally high land values and/or construction costs.

 

Seven out of ten active fractional resorts reports affiliation with an external exchange company. In addition, many resorts offer internal exchange through a club or private relationship between independent developers. Rental and resale programs are offered by more than half of all active resorts.

 

 

 

 

HFI and PRC Owners (from Fractional Interest Report by NorthCourse Leisure Real Estate Solutions)

 

HFI and PRC owners tend to be married empty-nesters in their mid to earlier fifties. Owners are very affluent, as 45.4% report a household income of $500,000 or more. Many hold membership in a country club (55%), and own some other form of vacation property in addition to their fractional interest.

 

The vast majority of owners report being satisfied with their fractional interest (92.7%). This includes 71.2% that are “very” satisfied and 21.5% that are “somewhat” satisfied. In addition more than 9 out of 10 owners either already have recommended fractional ownership to a friend or relative, or are willing to do so.

 

The most important purchase motivations, as reported by owners are: (1) location of the resort; (2) quality of finishes and furnishings; and (3) extent of on-site amenities and activities. The most important purchase hesitations are: (1) worry that they may not always receive their preferred time or home; (2) concerns about ability to resell; and (3) annual dues and maintenance fees.

 

Partners

 

Brues Y Fernandez  

 

The Company entered into a contract in March of 2007 with the Spanish construction company Brues Y Fernandez which contract contains a non-binding commitment to build the complete project and to supply part of the financing for the construction.

 

The Brues Y Fernandez Group is the general construction contractor for the project in Costa Rica. Its international experience is combined by personal commitment reflected in the willingness to share in the construction financing and contribute liability capital to obtain construction loans. The Brues Y Fernandez Group has substantial international experience, particularly in South America. As with all the cooperation partners, it has experience in similar projects and a wide range of references guaranteeing services of the highest quality.

 

Wimberly Allison Tong & Goo  

 

The Company is currently in midst of the project development. We were able to contract the world’s leading corporations for design, development and management for luxury Hotels and Resorts

 

Wimberly Allison Tong & Goo is an international architect firm based in England and the United States and will be taking on general architectural responsibility for the Costa Rica project. Over the last 50 years, Wimberly Allison Tong & Goo has established itself as leading design consultant and developer in the hospitality, leisure and entertainment industries with project experience in over 130 countries. Apart from various awards and prizes for international architectural services, the firm can boast highly regarded projects in the field of hospitality realization that amply demonstrate both its high creative and technical competence.

 

Gettys

 

 

 

Gettys is a global design firm specializing in interior design, interior architecture and procurement services for the hospitality industry, headquartered in Chicago, Illinois with offices in Miami, Irvine, and Hong Kong.

 

With nearly twenty years of experience in hotel design, Gettys is committed to providing sustainable design, an extensive portfolio of projects represents a diverse selection of hotel design and resort design project– from the Americas to the Caribbean and Asia   - with complex architecture, notable surroundings, and subtle project nuances makes Gettys an ideal, seasoned partner on any hospitality design project

 

The Hotel of Tomorrow (H.O.T.) Project is a groundbreaking initiative of Gettys. An exclusive think-tank, the H.O.T. Project seeks to conceptualize the future of the hospitality industry and foster the spirit of innovation through collaboration.

 

Ossenbach Pendones & Bonilla S.A.  

 

As the operative architect firm in Costa Rica, Ossenbach Pendones & Bonilla S. A. is locally responsible for implementing Wimberly Allison Tong & Goo's plans. The Company is pleased to have signed up Ossenbach Pendones & Bonilla S. A., in particular Mr. C. Ossenbach, because this architect firm with its 30-year track record has already completed such projects as a cooperation partner for an internationally recognized agency and enjoys an outstanding reputation in its own country.

 

Amstein + Walthert AG  

 

The engineering company Amstein + Walthert AG will be responsible for installing the high-performance building plant and in addition act as the quality controller for the Costa Rica resort and no doubt in future projects as well. Amstein + Walthert AG is one of the largest engineering companies in Switzerland; internationally awarded and renowned for its outstanding engineering services, which cover practically every aspect of construction including solar energy, geothermal energy and building plant.

 

Isselbaecher Food Service Equipment GmbH  

 

Isselbaecher Food Service Equipment GmbH will be responsible for kitchen planning and construction in the Costa Rica project, but probably also for other projects to follow. This is such a crucial issue that the Company is not prepared to put it in the hands of architects or general contractors, but wants to avail itself of the expertise of a specialist so that the demands of an international 5-star plus hotel operator can be satisfied. Since 1970, Isselbaecher Food Service Equipment GmbH has been the outstanding and competent contact worldwide for planning and implementing large-kitchen projects of all kinds, such as in hotels, restaurants, bistros, schools and universities and also hospitals etc.; a long reference list underscores the required experience.

 

Montejo & Associates  

 

The law firm Montejo & Associates has been engaged by the Company to handle all the legal aspects in conjunction with the acquisition of the site in Costa Rica and its development, in particular with respect to the envisaged use of running a hotel and also the commercial prominence of the project. Montejo & Associates is further contracted to support the Company in obtaining building permission.

 

Montejo & Associates was established in 1987, and is primarily devoted to real estate matters. The owner, Andr?s Montejo, is an attorney-at-law and notary public and was a President of the National Housing and Urban Development Institute. Apart from that, he taught property and ownership law (for over ten years) as

 

 

 

a professor at the University of Costa Rica. The law firm specializes and has proven expertise in the areas of importance for the Company: Residential Condominiums, Urban Development, Tourist Development, Tourist Concessions, Marine Costal Zone, Mortgages, Property Purchase, Houses and Buildings, Negotiation, Due Diligence, Property Survey, Purchase-Sale Agreements, Escrow Services, Title Transfers and Guaranties.

 

Tourist Demographics – Costa Rica

 

Between 1998 and 2005 the number of tourists visiting Costa Rica has almost doubled.

Costa Rica is being considered as one of the most attractive tourism destinations worldwide.

The demand for new hotel rooms is increasing per year by a minimum of 4%.

The yearly growth of Costa Rica’s tourism industry is 6.6%.

The “Plan Nacional de Turismo” (2002 – 2012) is expecting an average of 2.5 million tourists and an additional demand for accommodation facilities of 49,000 rooms by 2012 (2005: 32,000).

Over 60% of tourists’ come from the U.S. and Canada. The balance comes from Europe (approx. 30%), South America and the Caribbean (10%).

 

Marketing and Advertising Methods  

 

The Company intends to recruit or mandate third party expertise to help marketing and selling our hospitality related products. Our biggest effort will be focused on the marketing and sale of fractional interests in the Papagayo Princess Resort & Spa Hotel. Professional support for this endeavor is currently being evaluated and once a marketing partner is appointed remuneration will primarily be based on success.

 

Competition

 

Efforts to establish an affiliation of luxury tourist real estate developments that offer fractional ownership are fragmented and very competitive. Although we do not believe that we will compete directly with any other programs due to our novel approach, we do believe that we will compete indirectly with a number of companies, both private and public, that are active in developing and promoting fractional ownership in tourist destinations. Many of these competitors, such as “Exclusive Resorts”, “Four Seasons” and “St. Regis” are substantially larger and better funded than we are with significantly longer histories of real estate development. Nonetheless, we believe that competition in the development of luxury real estate properties that cater to the hospitality industry is based principally on the following factors:

 

the location of the development;

the level of service offered;

the terms of fractional ownership offered;

the preferential treatment of clients; and

the reputation of the business.

 

We anticipate that, as our business develops, we will respond successfully to these considerations.

 

Further, we believe that we have certain distinctive competitive advantages over all or many of our competitors that will enable us to progress the development of our plan of operation. The advantages include:

 

the location of its initial Costa Rican project;

client privileges;

environmental integrity; and

 

 

 

the willingness of our project managers to consider joint venture relationships with third parties to maximize resources in real estate development.

All of these factors in combination with the dedication of our personnel will enable us to be competitive in offering fractional ownership of luxury real estate dedicated to the hospitality industry.

 

Marketability

 

The products to be sold by the Company, fractional ownership interests in luxury real estate and private club memberships within the hospitality industry, are purchased by a diverse array or buyers within an established market place. The market for fractional ownership opportunities can be sourced on a worldwide basis. Fractional interest sales totaled approximately $1,075 million worldwide during 2004. Included in the total are $625 million in developer sales volume of fractional interests and $450 million in sales volume of destination clubs. This represents a substantial increase over 2003, when fractional interest developers sold an estimated $373 million in new fractional interests and destination clubs sold $140 million in memberships. A continuous market growth of over 30% per year (average) is expected for the next 10 years.

 

Patents, Trademarks, Licenses, Franchises, Concessions, Royalty Agreements and Labor Contracts

 

The Company currently has registered its “SunVesta” trademark in various countries.

 

Governmental and Environmental Regulation

 

The Company’s operations are subject to a variety of national, federal, state and local laws, rules and regulations relating to, among other things, worker safety and the use, storage, discharge and disposal of environmentally sensitive materials.

 

We believe that we are in compliance in all material respects with all laws, rules, regulations and requirements that affect our business. Further, we believe that compliance with such laws, rules, regulations and requirements do not impose a material impediment on our ability to conduct business.

 

Employees

 

The Company is a development stage company and currently has 5 employees. Our management uses consultants, attorneys, and accountants to assist in the conduct of our business

 

Reports to Security Holders

 

The Company’s annual report contains audited financial statements. We are not required to deliver an annual report to security holders and will not automatically deliver a copy of the annual report to our security holders unless a request is made for such delivery. We file all of our required reports and other information with the Securities and Exchange Commission (the “Commission”). The public may read and copy any materials that are filed by the Company with the Commission at the Commission’s Public Reference Room at 450 Fifth Street, N.W., Washington, D.C. 20549. The public may obtain information on the operation of the Public Reference Room by calling the Commission at 1-800-SEC-0330. The statements and forms filed by us with the Commission have also been filed electronically and are available for viewing or copying on the Commission maintained Internet site that contains reports, proxy and information statements, and other information regarding issuers that file electronically with the Commission. The Internet address for this site can be found at http://www.sec.gov.

 

 

 

ITEM 1A.

RISK FACTORS

 

The Company’s operations and securities are subject to a number of risks. Below we have identified and discussed the material risks that we are likely to face. Should any of the following risks occur, they will adversely affect our operations, business, financial condition and/or operating results as well as the future trading price and/or the value of our securities.

 

Risks Related to the Company’s Business

 

The Company’s limited operating history; anticipated losses; uncertainly of future results.

 

The Company has no operating history upon which an evaluation of our business prospects can be based. Rather, the Company’s prospects must be evaluated with a view to the risks encountered by a company in an early stage of development, particularly in light of the uncertainties relating to the acceptance of its business model.

 

We will be incurring costs to develop our luxury real estate and hospitality business. There can be no assurance that we will be profitable on a quarterly or annual basis. In addition, as we expand our business operations we will likely need to increase our operating expenses and increase our administrative resources. To the extent that such expenses are not subsequently followed by commensurate revenues, our business results of operations and financial condition would be materially adversely affected.

 

The Company has a historical record of losses which may continue.

 

The Company reported cumulative operating losses from January 1, 2005 (date of inception of development stage) until December 31, 2007 of $7,295,409. The historical record indicates that we have not realized revenue from our efforts and cannot provide us with any certainty that revenue is forthcoming or that revenue would be sufficient to support operations. The sum of these indicators creates uncertainty as to whether we will ever transition from losses to profits. Should we continue to incur losses we would be unable to meet our working capital requirements which inability would stifle operations.

 

Need for additional financing.

 

The Company has no revenue from operations and therefore is not able to meet operating costs. As such, we will need to raise capital within the next twelve months to implement our plan of operation. However, there can be no assurance that we will be able to raise the required capital or that any capital raised will be obtained on favorable terms. Failure to obtain adequate capital would significantly curtail the Company’s business.

 

Unpredictability of future revenues; potential fluctuations in the Company’s operating results.

 

Since we have no history of generating revenues within the niche luxury real estate market in which we intend to compete, we are unable to forecast revenues accurately. Our current and future expense levels are based largely on our own investment/operating plans and estimates of future revenue. The Company may be unable to adjust spending to compensate for any unexpected revenue shortfall or delay. Accordingly, any significant shortfall or delay in revenue in relation to our planned expenditures would have an immediate adverse affect on the Company’s business, financial condition, and results of operations.

 

Dependence on key personnel.

 

 

 

Our performance and operating results are substantially dependent on the continued service and performance of our managers, officers, and directors. We intend to hire additional management personnel as we move forward with our business model. Competition for such personnel is intense, and there can be no assurance that we will be able to retain our key management employees, or that we will be able to attract or retain highly qualified technical personnel in the future. The loss of the services of any of our key employees or the inability to attract and retain the necessary management personnel could have a material adverse effect upon the Company’s business.

 

Unproven acceptance of the Company’s approach to offering fractional ownership of luxury real estate.

 

Although the concept of fractional ownership of luxury real estate is not new to the hospitality industry, our plan of operation incorporates proven traditional elements of fractional ownership with unproven concepts yet to be offered. As a result, we do not know with any certainty whether our services and/or products will be accepted within the hospitality marketplace. If our services and/or products prove to be unsuccessful within the marketplace, such failure could materially adversely affect the Company’s financial condition, operating results, and cash flows.

 

Risks Related to the Company’s Stock

 

The market for our stock is limited and our stock price may be volatile.

 

The market for our common stock has been limited due to low trading volume and the small number of brokerage firms acting as market makers. Because of the limitations of our market and volatility of the market price of our stock, investors may face difficulties in selling shares at attractive prices when they want to. The average daily trading volume for our stock has varied significantly from week to week and from month to month, and the trading volume often varies widely from day to day.

 

The Company does not pay cash dividends.

 

The Company does not pay cash dividends. We have not paid any cash dividends since inception and have no intention of paying any cash dividends in the foreseeable future. Any future dividends would be at the discretion of our board of directors and would depend on, among other things, future earnings, our operating and financial condition, our capital requirements, and general business conditions. Therefore, shareholders should not expect any type of cash flow from their investment.

 

We incur significant expenses as a result of being quoted on the Over the Counter Bulletin Board, which may negatively impact our financial performance.

 

We incur significant legal, accounting and other expenses as a result of being listed on the Over the Counter Bulletin Board. The Sarbanes-Oxley Act of 2002, as well as related rules implemented by the Commission, has required changes in corporate governance practices of public companies. We expect that compliance with these laws, rules and regulations, including compliance with Section 404 of the Sarbanes-Oxley Act of 2002 as discussed in the following risk factor, may substantially increase our expenses, including our legal and accounting costs, and make some activities more time-consuming and costly. As a result, there may be a substantial increase in legal, accounting and certain other expenses in the future, which would negatively impact our financial performance and could have a material adverse effect on our results of operations and financial condition.

 

 

 

 

 

 

 

 

Our internal controls over financial reporting may not be considered effective in the future, which could result in a loss of investor confidence in our financial reports and in turn have an adverse effect on our stock price.

 

Pursuant to Section 404 of the Sarbanes-Oxley Act of 2002 we are required to furnish a report by our management on our internal controls over financial reporting. Such report must contain, among other matters, an assessment of the effectiveness of our internal controls over financial reporting as of the end of the year, including a statement as to whether or not our internal controls over financial reporting are effective. This assessment must include disclosure of any material weaknesses in our internal controls over financial reporting identified by management. If we are unable to continue to assert that our internal controls are effective, our investors could lose confidence in the accuracy and completeness of our financial reports, which in turn could cause our stock price to decline.

 

The Company’s shareholders may face significant restrictions on their stock.

 

The Company’s stock differs from many stocks in that it is a “penny stock.” The Commission has adopted a number of rules to regulate “penny stocks” including, but not limited to, those rules from the Securities Act as follows:

 

 

3a51-1

which defines penny stock as, generally speaking, those securities which are not listed on either NASDAQ or a national securities exchange and are priced under $5, excluding securities of issuers that have net tangible assets greater than $2 million if they have been in operation at least three years, greater than $5 million if in operation less than three years, or average revenue of at least $6 million for the last three years;

 

15g-1

which outlines transactions by broker/dealers which are exempt from 15g-2 through 15g-6 as those whose commissions from traders are lower than 5% total commissions;

 

15g-2

which details that brokers must disclose risks of penny stock on Schedule 15G;

 

15g-3

which details that broker/dealers must disclose quotes and other information relating to the penny stock market;

 

15g-4

which explains that compensation of broker/dealers must be disclosed;

 

15g-5

which explains that compensation of persons associated in connection with penny stock sales must be disclosed;

 

15g-6

which outlines that broker/dealers must send out monthly account statements; and

 

15g-9

which defines sales practice requirements.

Since the Company’s securities constitute a “penny stock” within the meaning of the rules, the rules would apply to us and our securities. Because these rules provide regulatory burdens upon broker-dealers, they may affect the ability of shareholders to sell their securities in any market that may develop; the rules themselves may limit the market for penny stocks. Additionally, the market among dealers may not be active. Investors in penny stock often are unable to sell stock back to the dealer that sold them the stock. The mark-ups or commissions charged by the broker-dealers may be greater than any profit a seller may make. Because of large dealer spreads, investors may be unable to sell the stock immediately back to the dealer at the same price the dealer sold the stock to the investor. In some cases, the stock may fall quickly in value. Investors may be unable to reap any profit from any sale of the stock, if they can sell it at all.

 

Shareholders should be aware that, according to Commission Release No. 34-29093 dated April 17, 1991, the market for penny stocks has suffered from patterns of fraud and abuse. These patterns include:

 

 

 

 

 

 

 

control of the market for the security by one or a few broker-dealers that are often related to the promoter or issuer;

 

manipulation of prices through prearranged matching of purchases and sales and false and misleading press releases;