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SEC Comment Letter for CHYRON CORP (CIK 0000020232) — Jun 9, 2005

CHYRON CORP (CIK 0000020232)
Date: June 9, 2005 · CIK: 0000020232 · Accession: 0000000000-05-028722

AI Filing Summary & Sentiment

File numbers found in text: 000-24511

Referenced dates: June 6, 2005

Date
June 9, 2005
Author
Gary Todd
Form
UPLOAD
Company
CHYRON CORP (CIK 0000020232)

Letter

June 9, 2005 By U.S. Mail and facsimile to (631) 845-3896 Mr. Jerry Kieliszak Chief Financial Officer Chyron Corporation 5 Hub Drive Melville, NY 11747

RE: Chyron Corporation Form 10-K for the fiscal year ended December 31, 2004 Form 10-Q for the quarterly period ended March 31, 2005 File No. 000-24511

Dear Mr. Jerry Kieliszak:

We have reviewed your response to our letter dated June 6, and have the following additional comment.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the year ended December 31, 2004

Item 7. Management`s Discussion and Analysis of Financial Condition and Results of Operations - Page 16

Liquidity and Capital Resources - Page 19 1. We refer to the response to comment 2. We see from a Form 8-K dated February 24, 2005 that you are required to maintain certain levels of tangible net worth under the credit facility with the bank. We see from your financial statements that you have reported a shareholders` deficit in recent periods. Accordingly, future filings should clarify how you define or measure tangible net worth for purposes of complying with that covenant.

* * * *

As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your response that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.

You may contact Patrick Enunwaonye, Staff Accountant, at (202) 824-5529 or me, at (202) 942-2862 if you have questions regarding comments on the financial statements and related matters. In this regard, do not hesitate to contact Brian Cascio, Accounting Branch Chief , at (202) 942-1791 with any other concerns.

Sincerely,
Gary Todd
Review Accountant
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Show Raw Text
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Mail Stop 0306

June 9, 2005

By U.S. Mail and facsimile to (631) 845-3896

Mr. Jerry Kieliszak
Chief Financial Officer
Chyron Corporation
5 Hub Drive
Melville, NY 11747

	RE:	Chyron Corporation
		Form 10-K for the fiscal year ended December 31, 2004
		Form 10-Q for the quarterly period ended March 31, 2005
		File No. 000-24511

Dear Mr. Jerry Kieliszak:

      We have reviewed your response to our letter dated June 6,
2005
and have the following additional comment.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended December 31, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations - Page 16

Liquidity and Capital Resources - Page 19
1. We refer to the response to comment 2.  We see from a Form 8-K
dated February 24, 2005 that you are required to maintain certain
levels of tangible net worth under the credit facility with the
bank.
We see from your financial statements that you have reported a
shareholders` deficit in recent periods. Accordingly, future
filings
should clarify how you define or measure tangible net worth for
purposes of complying with that covenant.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Patrick Enunwaonye, Staff Accountant, at
(202)
824-5529 or me, at (202) 942-2862 if you have questions regarding
comments on the financial
statements and related matters. In this regard, do not hesitate to
contact Brian Cascio,  Accounting Branch Chief , at (202) 942-1791
with any other concerns.

							Sincerely,

							Gary Todd
							Review Accountant
??

??

??

??

Mr. Jerry Kieliszak
Chyron Corporation.
May 6, 2005
Page 1

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