Re: | Nocopi Technologies, Inc. Form 10-KSB for the year ended December 31, 2007 Form 10-Q for the quarter ended March 31, 2008 File No. 0-20333 |
1. | Reference is made to the line item Reversal of accounts payable and accrued expenses in the amount of $175,900 included under Other income (expense) on the face of your statements of operations. We note that you disclose in Note 6 to the consolidated financial statements that the $175,600 is related to the reversal of certain accounts payable and accrued consulting fees that the Company, with legal counsel, has determined to be no longer statutorily payable. Please tell us in greater detail the nature, facts and circumstances surrounding the accounts payable and accrued expense balances that were included as part of the reversal. Your response to us should include, but not be limited to, a detailed listing of the amounts included in the reversal; when each amount was originally recorded by management; how management determined or calculated each of the liabilities at the time they were originally recorded; and the triggering event and reason(s) for which you believe it was appropriate to reverse the accounts payable balance and accrued expense amounts during fiscal 2007, the majority of which was reversed during the quarter ended September 30, 2007. We may have further comment upon receipt of your response. |
2. | Please revise your statements of stockholders equity in the future to include a total column. |
3. | We note that you disclose the Companys three largest non-affiliated customers accounted for approximately 86% and 65% of revenues, and 100% and 75% of net accounts receivable at December 31, 2007 and 2006, respectively. Please revise your disclosure in future filings to separately disclose the amount or percentage of revenue derived from any single customer representing 10% or more of total revenues. Please also provide disclosures for any single customers with accounts receivable balances representing 10% or more of total accounts receivable. Refer to paragraph 39 of SFAS No. 131. |
4. | We note from your disclosure that since becoming Chief Executive Officer in February 2000, Dr. Feinstein has not received cash or non-cash compensation for his services as an officer of the Company. Please note that historical financial statements should reflect reasonable compensation levels even if the services were contributed by the officer. In cases where no charges were made or are unreasonably low, and if material to an understanding of operating results, historical statements should be revised to reflect the value of the services rendered as a capital contribution. In this regard, please tell us why you believe your accounting treatment, or lack thereof, is appropriate and provide us the guidance you relied upon which support your conclusions. Alternatively, you may revise your financial statements to reflect reasonable compensation levels for the services contributed. We may have further comment upon receipt of your response. |
Best regards, |
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/s/ Michael A. Feinstein, M.D. | ||||
Michael A. Feinstein, M.D. | ||||
cc: | Rudolph A. Lutterschmidt, Chief Financial Officer Effie Simpson Jean Yu |