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scion

02/05/09 8:06 PM

#10515 RE: Bill_Investor #10470

Revenue Recognition

We have three main sources of revenue: drug testing and related services, training and online certification, and security services provided by an allied company.

Drug testing: we fulfill orders for drug testing services, wherein we are responsible for the performance and data maintenance related to employee drug testing for its clients. We do not perform the drug tests, but we fulfill the order through our network of third party labs and other drug testing facilities.

Revenue is recognized when the drug testing has been completed by the lab and the customer has been invoiced for the services.

We have low bad debt levels because our policy is to deal with large well-positioned firms that pay monthly. Because we track these company's activities daily, we are constantly aware of our position and therefore can demand and receive timely payments as we provide on-going compliance services. Pursuant to EITF 99-19, we are responsible for fulfilling a customer's order, including whether the service is acceptable and therefore bears the risks and rewards of principal.

As such, we have elected to record the gross amounts of the contracts. Our service agreements rarely include multiple parts that would have a material impact on the recognition of revenue. As such, we have created our revenue recognition policies pursuant to EITF 00-21.

FORM 10-12G/A
http://www.sec.gov/Archives/edgar/data/1426567/000134506708000042/form10.htm