SEC Company Response from REYNOLDS & REYNOLDS CO (CIK 0000083588) — Oct 14, 2005
REYNOLDS & REYNOLDS CO (CIK 0000083588)
Date: Oct. 14, 2005 · CIK: 0000083588 · Accession: 0000950152-05-008153
AI Filing Summary & Sentiment
File numbers found in text: 001-10147
Referenced dates: September 16, 2005
Letter
Office of Computers and Online Services Division of Corporation Finance Securities and Exchange Commission Form 10-Q for Fiscal Quarter Ended December 31, 2004 Form 10-Q for Fiscal Quarter Ended March 31, 2005 Form 10-Q for Fiscal Quarter Ended June 30, 2005 File No. 001-10147
Dear Mr. Wilson:
This is to confirm the conversation today between Christopher White, Staff Accountant and our counsel, John J. Huber of Latham & Watkins, LLP, to the effect that The Reynolds and Reynolds Company (the “Company”) needs additional time to prepare the position paper on its revenue recognition policy and to respond to the non-revenue recognition comments in the Staff’s comment letter dated September 16, 2005. As discussed with Mr. White, management, particularly Gregory Geswein, who became Chief Financial Officer on August 23, 2005, is working with the Company’s auditors and consultants, including Mr. Huber, who became counsel to the Company in September 2005, to address the Staff’s comments in a thorough and complete fashion, so that the comments can be resolved without the necessity of another comment letter. Also, as discussed with Mr. White, Mr. Huber will update the Staff about the Company’s schedule to respond by October 21, 2005.
Sincerely,
/s/ Joyce Murty
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CORRESP
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The Reynolds and Reynolds Company
October
13, 2005
Craig Wilson
Senior Assistant Chief Accountant
Office of Computers and Online Services
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re:
The Reynolds and Reynolds Company
Form 10-K for Fiscal Year Ended September 30, 2004
Form 10-Q for Fiscal Quarter Ended December 31, 2004
Form 10-Q for Fiscal Quarter Ended March 31, 2005
Form 10-Q for Fiscal Quarter Ended June 30, 2005
File No. 001-10147
Dear Mr. Wilson:
This is to confirm the conversation today between Christopher White, Staff Accountant and our
counsel, John J. Huber of Latham & Watkins, LLP, to the effect that The Reynolds and Reynolds
Company (the “Company”) needs additional time to prepare the position paper on its revenue
recognition policy and to respond to the non-revenue recognition comments in the Staff’s comment
letter dated September 16, 2005. As discussed with Mr. White, management, particularly Gregory
Geswein, who became Chief Financial Officer on August 23, 2005, is working with the Company’s
auditors and consultants, including Mr. Huber, who became counsel to the Company in September 2005,
to address the Staff’s comments in a thorough and complete fashion, so that the comments can be
resolved without the necessity of another comment letter. Also, as discussed with Mr. White, Mr.
Huber will update the Staff about the Company’s schedule to respond by October 21, 2005.
Sincerely,
/s/ Joyce Murty
Joyce Murty
Senior Corporate Counsel
cc:
Stephen Krikorian, Accounting Branch Chief
Thomas Ferraro, Senior Staff Accountant
Christopher White, Staff Accountant
P.O. Box 1824
Dayton, OH 45401
937.485.2000