SEC Comment Letter for CACHE INC (CIK 0000350199) — Mar 11, 2005
CACHE INC (CIK 0000350199)
Date: March 11, 2005 · CIK: 0000350199 · Accession: 0000000000-05-011698
AI Filing Summary & Sentiment
Letter
Mail Stop 0308 March 11, 2005 Brian Woolf Chairman and Chief Executive Officer Cache, Inc. 1440 Broadway New York, NY 10018
RE: Cache, Inc. Item 4.01 Form 8-K filed February 16, 2005 File No. 0-10345
Dear Mr. Woolf:
We have reviewed the above referenced filing and have the following comments. We welcome any questions you may have about our comments. Feel free to contact us at the telephone numbers listed at the end of this letter.
1. We note that KMPG will decline to stand for re-appointment at a future date. You will need to file an amendment to this Form 8-K disclosing the date that KPMG ceases to be your principal accountant. We would expect your amendment to be able to say that there were no disagreements through February 11, 2005 and there are still no disagreements through the last day of their engagement, if true. Please revise when appropriate.
2. Your filing did not include a comma in your corporate name on the cover of the filing; however, it appears from other information that it is part of your legal name. Please correct in future filings or advise.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Brian Woolf Cache, Inc. March 11, 2005 Page 2
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the disclosures in the filing;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
? the company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing.
The amendment should include an updated letter from the former accountants confirming that they agree with the revised disclosure, if true. Please file the supplemental information requested above as correspondence on EDGAR. Any questions regarding the above should be directed to me at (202) 942-1809, or in my absence, to Robert Benton at (202) 942-1811.
Sincerely,
Robert Burnett
Staff Accountant
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Mail Stop 0308
March 11, 2005
Brian Woolf
Chairman and Chief Executive Officer
Cache, Inc.
1440 Broadway
New York, NY 10018
RE: Cache, Inc.
Item 4.01 Form 8-K filed February 16, 2005
File No. 0-10345
Dear Mr. Woolf:
We have reviewed the above referenced filing and have
the
following comments. We welcome any questions you may have about
our
comments. Feel free to contact us at the telephone numbers listed
at
the end of this letter.
1. We note that KMPG will decline to stand for re-appointment at a
future date. You will need to file an amendment to this Form 8-K
disclosing the date that KPMG ceases to be your principal
accountant.
We would expect your amendment to be able to say that there were
no
disagreements through February 11, 2005 and there are still no
disagreements through the last day of their engagement, if true.
Please revise when appropriate.
2. Your filing did not include a comma in your corporate name on
the
cover of the filing; however, it appears from other information
that
it is part of your legal name. Please correct in future filings
or
advise.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
Brian Woolf
Cache, Inc.
March 11, 2005
Page 2
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosures in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
? the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.
The amendment should include an updated letter from the
former
accountants confirming that they agree with the revised
disclosure,
if true. Please file the supplemental information requested above
as
correspondence on EDGAR. Any questions regarding the above should
be
directed to me at (202) 942-1809, or in my absence, to Robert
Benton
at (202) 942-1811.
Sincerely,
Robert Burnett
Staff Accountant
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