Univec Inc (UNVC)

[stockmasterflash]

This comment by the SEC shows the true scumbag character of David Dalton

*** UNVC was a scam whereby UNVC bought product from a company owned by Dalton and then sold it to a different company owned by Dalton. ****

Note 4. Significant Accounting Policies, page F-7

-Revenue Recognition, page F-8

10. Please refer to prior comment 15. You previously disclosed
that
98% and 91% of your revenue for 2004 and 2003, respectively, was
derived from sales to one customer that is owned by your
president.
We have the following specific questions regarding your response:

* You state in your response that you have latitude in
establishing
the price of goods. You also state that you have discretion in
supplier selection and that that you retain absolute control over
which product is provided to the user. We note that your
president
is also the owner of your primary group purchasing operations
customer, PSI. In addition, we note your disclosure on page 9
that
Univec employs only four persons and that you utilize employees of
PSI to provide certain administrative services. Please provide us
with a revised analysis that takes into account the related party
nature of these transactions in evaluating the factors specified
in
EITF 99-19.

* Your response to prior comment 15 discusses latitude in
establishing prices in the context of the relationship between you
and the supplier. Please note the guidance in EITF 99-19 in this
regard refers to the establishment of prices between you and the
customer. Please provide us with a revised analysis of this
factor
as it relates to the relationship between you and your customer.
Your analysis should include specific discussion of how the
related
party nature of your negotiations with PPSI impacts this factor.

https://www.sec.gov/Archives/edgar/data/1029825/000000000005063145/filename1.txt

Note 17. Concentrations, page F-15

11. Please refer to prior comment 14. You state that Pharmacy
Services, Inc. is not a related party as defined in SFAS 57. You
further state that PSI is an affiliated private company wholly
owned
by the President of Univec. Please note the definition of related
party in Appendix B of SFAS 57 includes affiliated parties, which
are
defined as "parties that, directly or indirectly through one or
more
intermediaries, control, are controlled by, or are under common
control with an enterprise." We note from your disclosures on
page
18 of the Form 10-K/A that your president is the single largest
shareholder of Univec, owning 39.4% of the outstanding common
stock
of Univec as of August 31, 2004. Based on these facts, it appears
that PSI is a related party as defined in SFAS 57. Please revise
to
provide the required disclosures of paragraphs 2-4 of SFAS 57.

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