Securities and Exchange Commission Washington DC

New Post Public Reply Private Reply Replies (0) Message Board
JCN


Securities and Exchange Commission

Washington DC 20549



Att: James Lopez (for) John Reynolds

Assistant Director



Tuesday, April 10, 2012



Dear Mr Lopez,



I am forwarding this letter to you regarding our phone conversation Thursday, April 5th 2012 inquiring about the report filing requirements needed by eMax Holdings Corp (also known as eMax Worldwide, Inc.) to once again become fully reporting with your agency.



For over three years now, eMax has retained the firm McMullen Associates as our securities counsel to assist with reporting to your agency. Unfortunately, at this time it appears that the firm has yet to perform while payments are still being made. Last year after receiving the first correspondence from your office, I submitted the letter to our securities counsel and was instructed to write a response stating that they would be in contact with you. At this time, I realize there is a great possibility that they never contacted you, even though we requested follow up numerous occasions.



I know, as the CEO, I am fully responsible for the filings of the company. Now I find myself in a horrible situation as we are under a temporary suspension. We have tried to speak to our securities counsel directly all week to get an answer regarding this matter and have found them unattainable.



With this known fact, I contacted you directly and humbly request the following:



1.) A six month period allowance to submit 3 years of 10Q's and 10K's with audited financials, for the sole purpose of becoming fully reporting again with the SEC. This will provide us with enough time to secure new securities counsel that can work with our auditors.



2.) Allow for us to file an amendment to the Form 15 stating that the Form 15 was filed in error and is withdrawn.



3.) We will register such re-sales or provide an analysis of any exemption from registration that we believe is available and as relating to the event listed here and as noted in your letter to our office dated January 26, 2012 “The Form 8-K dated June 22, 2011 indicates that Mindpix Corp. will issue 400,000,000 shares…in exchange for all the common stock in eMax Media, Inc.” and that “the eMax Worldwide, Inc. (“EMXC&rdquo , shareholders are entitled to receive one share of common stock dividends in Mindpix Corp. for every 32 shares of common stock that is owned in EMXC. This transaction appears to be a spin-off of Mindpix Corp., and you appear to be acting as an underwriter in the issuance of the 400 million Mindpix shares to the shareholders of eMax Worldwide, Inc.”





Provided below is a copy of the correspondence that was sent to our office dated January 26, 2012. As previously directed by our securities counsel attached you will find the letter we first sent to your office on July 14, 2011.



At this time, I wish to thank you for your time, consideration and understanding in this important matter. I would be humbly appreciative if we were allowed the time requested to file the necessary reports to your office and as for the reason we are retaining new securities counsel to aid our office with these filing responsibilities.



Sincerely Yours,



Roxanna Weber

S/Roxanna Weber

CEO/Chairman





Attachments



1. Letter from the SEC to eMax Worldwide, Inc.



January 26, 2012

Via E-mail

Roxanna Weber

Chairman, President and Director

eMax Worldwide, Inc.

1512 South 1100 East, Suite B

Salt Lake City, UT 84105



Re: eMax Worldwide, Inc.

Form 15

Filed January 9, 2012

File No. 033-20394-D



Dear Ms. Weber:



We note that eMax Worldwide, Inc. filed a Form 15 on January 9, 2012 indicating there

are approximately 2,881 holders of record of your common stock. As requested in our March

28, 2011 letter, please file an amendment to the Form 15 stating that the Form 15 was filed in

error and is withdrawn. In the event eMax Worldwide, Inc. decides to appeal the Division’s

decision and not withdraw the Form 15, you should follow the procedures for doing so on the

Securities and Exchange Commission’s website. Those procedures can be found at:

http://www.sec.gov/info/edgar/cfedgarguidance.htm.

We further note the outstanding comments from our letter dated June 30, 2011 regarding

your Form 8-K filed on June 23, 2011. We re-issue the following comments, as we have not

received a response as of the date of this letter. Please file all required reports, including any

past due reports, and respond to our comments below within ten business days. If you do not

believe our comments apply to your facts and circumstances, please tell us why in your response.

1. The Form 8-K dated June 22, 2011 indicates that Mindpix Corp. “will issue 400,000,000

shares…in exchange for all the common stock in eMax Media, Inc.” and that “the eMax

Worldwide, Inc. (“EMXC&rdquo , shareholders are entitled to receive one share of common

stock dividends in Mindpix Corp. for every 32 shares of common stock that is owned in

EMXC.” This transaction appears to be a spin-off of Mindpix Corp., and you appear to

be acting as an underwriter in the issuance of the 400 million Mindpix shares to the

shareholders of eMax Worldwide, Inc. Please advise us as to why you believe

registration under the Securities Act of 1933 is not required. See Division of Corporation

Finance Staff Legal Bulletin No. 4, Sept. 16, 1997, available at

http://www.sec.gov/interps/legal/slbcf4.txt.

Roxanna Weber

eMax Worldwide, Inc.

January 26, 2012







Page 2



2. It appears that the recipients of Mindpix Corp.’s shares would act as underwriters in

resales of those shares, requiring registration under the Securities Act of 1933 for such

resales, absent an available exemption. Please confirm that you will register such resales

or provide an analysis of any exemption from registration that you believe is available.



3. It appears that eMax Worldwide, Inc. continues to have a duty to file reports under

Section 15(d) of the Securities Exchange Act of 1934. Please file all required periodic

reports, including any past due reports.



Please respond to this letter within ten business days by amending your filing, by

providing the requested information, or by advising us when you will provide the requested

response. If you do not believe our comments apply to your facts and circumstances or do not

believe an amendment is appropriate, please tell us why in your response.

You may contact Erin Wilson at (202) 551-6047 or James Lopez at (202) 551-3536 with

any questions.



Sincerely,

/s/ James Lopez (for)

John Reynolds

Assistant Director





2. Letter sent to your office from eMax Worldwide



July 14, 2011

Securities and Exchange Commission

Washington DC 20549



To Whom It May Concern,



As it pertains to your letter dated Jun 30, 2011, please know that our office has

forwarded this letter to our legal securities counsel

McMullen And Associates LLC

10701 McMullen Creek Parkway

Charlotte, NC28226

for and your office can expect correspondence from their office and answering your questions correctly as soon as possible.



As it stands however, our office does plan to properly file through our legal securities office all necessary reports and filings that are required for our company to become fully reporting and regarding all dividends that are being issued in our company eMax Worldwide in addition to announced dividends related to the company Mindpix, Corp,



Should you have any further questions, do not hesitate to contact our office or Mr McMullen office directly.



Sincerely Yours,



Roxanna Weber, President. And CEO


http://www.macreportmedia.com/ViewSubmission....uest=13996

Emax Holdings Corp (EMXC) Stock Research Links

EMXC Board Company Profile Buy Rating Time & Sales News Filings Financials
Scroll down for more posts ▼

Top 10 Most Recent News Articles

Chery Auto's Bold Green Tech Showcase at 2026 Summit

Updated Category News Views 1

Chery Auto Puts Eco Tech at Front and Center You know, Chery Auto isn't just manufacturing cars anymore—it's shaping an entire lifestyle. For the uninitiated, they’re calling in everyone worth knowing to their headquarters in Wuhu, China, come October 18 through 24. The 2026 Chery International User Summit is kind of a big deal this year with nearly 20 new green...

Continue Reading
Invictus Pharmacy Secures LegitScript Certification Status

Updated Category News Views 3

A New Chapter for Invictus Pharmacy In a world tangled up in red tape, Invictus Pharmacy somehow managed to cut a clear path by earning the LegitScript Healthcare Merchant Certification. Now, it seems like they've joined the ranks of the big players, including the likes of Amazon Pharmacy. It’s not just a shiny badge on their website, folks. It’s better access to...

Continue Reading
Fast Guard Elevates Nationwide Fire Watch Mission

Updated Category News Views 1

Fast Guard: The Unseen Shield Behind Property Safety Hollywood, Florida might be best known for its sun-kissed beaches, but in the world of fire safety, it’s the nerve center for emergency fire watch response. Fast Guard Service isn’t just any run-of-the-mill security outfit; it’s rapidly becoming the unsung hero of property managers across the nation. When those...

Continue Reading
Shanghai's Arts Carnival Fuses Tech and Culture

Updated Category News Views 1

Shanghai Heralds New Era in Arts with Carnival Coming in hot, Shanghai's ready to shake up the city's cultural scene with the 2026 International Audio-Visual Arts Carnival. It's happening in Jing'an District from September 24 to October 18, promising an experience that fuses travel, technology, and art. Just about anyone can catch a break from their daily grind and dive...

Continue Reading
PayPal Under Investigation: Legal Battles Intensify

Updated Category News Views 2

A Bumpy Ride for PayPal's Investors Back in 2025, PayPal was beaming about new growth strategies, filling the air with grandiose promises. Fast forward to February 2026, and the script had flipped entirely. Earnings came in nasty and disappointing, particularly in the Branded Checkout front. Adding to the chaos was their CEO unceremoniously taking the high road out the...

Continue Reading
Portland Craft Chocolate Fest: Oct. Flavor Fiesta

Updated Category News Views 4

If you're a chocolate lover residing in or around the Portland area, you're in for a treat. The Portland Craft Chocolate Festival is back, running from October 2-4. This festival is not just any community event; it's going to be a massive chocolate bonanza featuring over 45 local chocolate artisans, bakers, and confectioners. And let me tell you, this year they’re...

Continue Reading
2026 Lantern Festival Shines in Kunshan Amid Tensions

Updated Category News Views 1

Lanterns Illuminate Cross-Strait Relations Under the shadow of geopolitical tensions, the 2026 Cross-Strait (Kunshan) Mid-Autumn Lantern Festival kicked off with a splash on September 16. Held in Kunshan, Suzhou, this cultural festival offers a rare glimpse of cooperation and shared cultural celebration across the Taiwan Strait. Through lantern displays, art exhibitions,...

Continue Reading
Arizona Voters Demand Clear Plans for 2026 Election

Updated Category News Views 3

A Shift in Voter Expectations: Clear Actions Needed Arizona voters have spoken, and they aren't looking for the same old political song and dance anymore. They crave something meatier—action, not just words. Heading into the 2026 general election, folks in the Grand Canyon State are demanding concrete solutions and straightforward answers from those who seek to lead...

Continue Reading
Quay Dominates 2026 Sunglasses Review for Variety

Updated Category News Views 2

Sunglasses Designed for Every Face Type When it comes to picking the right pair of shades, face shape is only part of the equation. Expert Consumers just dropped their 2026 verdict, spotlighting Quay as the go-to brand for those wider faces, tricky nose bridges, and the noggins that run a tad larger than average. Forget what you heard about one-size-fits-all. This...

Continue Reading
Ensuring Your Radon Mitigation System Stays Effective

Updated Category News Views 2

Radon Mitigation: A Critical Measure for Home Safety Homeowners, you're probably aware of the ticking health time bomb known as radon. Not just an annoying gas, this colorless, odorless beast lurks quietly, threatening family health if not managed right. Mitch Kelley, a specialist in radon testing with Basement Solutions in Mankato, Minnesota, lays out a no-fuss guide to...

Continue Reading
More News Articles