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The firm did not identify and evaluate a misstatement in a required disclosure under FASB ASC Topic 350 Intangibles – Goodwill and Other. (AS 2810.30 and .31)

The firm did not identify and evaluate the issuer's omission of certain required disclosures under FASB ASC Topic 350 Intangibles – Goodwill and Other. (AS 2810.30 and .31)

With respect to certain finite-lived intangible assets the firm did not perform sufficient procedures to evaluate whether the assets were appropriately accounted for in conformity with FASB ASC Topic 350 Intangibles—Goodwill and Other. Specifically the firm did not evaluate the appropriateness of (1) the classification of the assets as finite-lived intangible assets and (2) the useful lives assigned to the assets when no contractual term was present including the amortization expense recorded thereafter. (AS 2301.08 and .11; AS 2810.03)

The issuer entered into an agreement ('acquisition agreement') to acquire a license that granted it the rights to sell certain products and it recorded the license agreement ('license agreement') as an intangible asset. The acquisition and license agreements required the issuer to among other terms pay royalty fees on future net sales (with guaranteed minimum royalty fees) pay an external party for future advisory services and issue convertible preferred stock. The issuer recorded certain of the payments to the external party as part of accounting for the transaction. The firm did not evaluate whether the future royalty payments should have been recorded as part of accounting for the transaction in conformity with FASB ASC Topic 805 Business Combinations. In addition the firm did not evaluate whether it was appropriate to recognize certain of the payments to the external party as part of the accounting for the transaction and not recognize the remaining payments in conformity with FASB ASC Topic 805. (AS 2810.30)

The firm did not identify and evaluate a departure from the applicable financial reporting framework related to the issuer's omission of certain disclosures related to intangible assets required by the framework. (AS 2810.30 and .31)

The firm did not identify and evaluate a departure from the applicable financial reporting framework related to the issuer's omission of certain disclosures related to intangible assets required by the framework. (AS 2810.30 and .31)

The firm did not identify and evaluate that the method the issuer used to estimate the impairment of certain intangible assets was not in conformity with FASB ASC Topic 350. (AS 2810.30) Unrelated to our review the issuer reevaluated its accounting for these assets and concluded that misstatements existed that had not been previously identified. The issuer subsequently filed a Form 8-K indicating that its previously issued financial statements should not be relied on and corrected these misstatements in a subsequent filing.

The firm did not identify and evaluate that the issuer's omission of certain disclosures for assets measured at fair value on a nonrecurring basis was not in conformity with FASB ASC Topic 820 Fair Value Measurements. (AS 2810.30 and .31)

The firm did not identify and evaluate that the method the issuer used to estimate the impairment of certain intangible assets was not in conformity with FASB ASC Topic 350 Intangible Assets Goodwill and Other. (AS 2810.30) Unrelated to our review the issuer reevaluated its accounting for these assets and concluded that material misstatements existed that had not been previously identified. The issuer subsequently filed a Form 8-K indicating that its previously issued financial statements should not be relied on and corrected these misstatements in a subsequent filing.

The issuer's policy was to group long-lived assets including customer-relationship intangible assets together at the reportable segment level for purposes of evaluating its long-lived assets for possible impairment. The following deficiencies were identified: · The firm did not evaluate beyond reading the issuer's accounting policy whether the issuer's determination that the lowest level of identifiable and independent cash flows available were at the issuer's reportable segments level was in conformity with FASB ASC Subtopic 360-10 Property Plant and Equipment - Overall. (AS 2501.11; AS 2810.30)

During the year the issuer acquired an intangible asset as part of a business combination. The issuer classified the intangible asset as finite-lived and began amortizing the intangible asset over its estimated useful life. The firm did not identify or appropriately address a departure from GAAP related to issuer's classification of the intangible asset as finite-lived and recording of amortization which was not in conformity with FASB ASC Topic 350 Intangibles—Goodwill and Other for this type of intangible asset. (AS 2810.30)

The firm did not identify and evaluate a departure from IFRS related to an error in the issuer's disclosure of the intangible asset within its impairment footnote in accordance with IAS 1 Presentation of Financial Statements. (AS 2810.30 and .31)

The firm did not identify and appropriately address departures from GAAP related to the financial statement presentation and disclosures associated with the issuer's intangible assets. The issuer included an inaccurate disclosure in the notes to the financial statements that an impairment loss related to the intangibles had been recorded when in fact the issuer had not recorded an impairment. Further the issuer did not disclose the estimated aggregate amortization expense for each of the five succeeding fiscal years as required by FASB ASC Topic 350 Intangibles — Goodwill and Other and did not reflect the related amortization expense as part of the reconciliation of net income and net cash flow from operating activities in its statement of cash flows as required by FASB ASC Topic 230 Statement of Cash Flows. (AS 2810.30 and .31)

The issuer performed a qualitative assessment to determine whether any of the acquired intangible assets were impaired. The firm did not sufficiently evaluate whether the issuer considered certain relevant events or changes in circumstances in conformity with FASB ASC Topic 350 Intangibles —Goodwill and Other including the issuer's recurring operating losses net losses negative cash flows from operations and substantial doubt about the issuer's ability to continue as a going concern when evaluating the issuer's qualitative assessment. (AS 2810.03 and .30)

The firm did not identify and evaluate the issuer's omission of certain disclosures required under FASB ASC Topic 820 Fair Value Measurement. (AS 2810.30 and .31) In connection with our review the issuer reevaluated its disclosures related to these intangible assets and determined that certain disclosures were omitted. The issuer corrected these omissions in the amended filing discussed below.