SEC Comment Letter for ITERIS, INC. (ITI) (CIK 0000350868) — May 23, 2005
ITERIS, INC. (ITI) (CIK 0000350868)
Date: May 23, 2005 · CIK: 0000350868 · Accession: 0000000000-05-025460
AI Filing Summary & Sentiment
File numbers found in text: 333-121942
Referenced dates: March 17, 2005
Letter
March 24, 2005 Via U.S. Mail and Fax (949) 932-3601 Gregory A. Miner, CEO Iteris Holdings, Inc. 1515 South Manchester Avenue Anaheim, CA 92802 Form 8-K filed October 12, 2004 File No. 0-10605
RE: Iteris, Inc. Registration Statement on Form S-3 Filed January 10, 2005 File No. 333-121942
Dear Mr. Miner:
We have reviewed your response letter dated March 17, 2005, and have the following comment. 1. Provide an expanded response to prior comment 1 of our February 4, 2005 letter that clearly explains the basis for management`s belief that the company`s disclosure controls and procedures were effective during the relevant periods in light of the numerous significant deficiencies identified by Ernst & Young. In your response, please address the consideration management gave to the nature and extent of the adjusting entries that you listed for us in your letter of March 17, 2005. Among other things, we note that many of the adjusting journal entries were made on a post-closing basis and were identified by Ernst & Young, not management. Also supplement your response to acknowledge the existence of the other significant deficiencies in addition to the delays in the reporting process.
* * * *
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR.
You may contact Derek Swanson, Staff Attorney, at (202) 824- 5526, or me at (202) 942-1990 with any other questions.
Sincerely,
Michele M. Anderson
Legal Branch Chief
Show Raw Text
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<TEXT>
Mail Stop 4-7
March 24, 2005
Via U.S. Mail and Fax (949) 932-3601
Gregory A. Miner, CEO
Iteris Holdings, Inc.
1515 South Manchester Avenue
Anaheim, CA 92802
RE: Iteris, Inc.
Registration Statement on Form S-3
Filed January 10, 2005
File No. 333-121942
Form 8-K filed October 12, 2004
File No. 0-10605
Dear Mr. Miner:
We have reviewed your response letter dated March 17, 2005, and
have
the following comment.
1. Provide an expanded response to prior comment 1 of our February
4,
2005 letter that clearly explains the basis for management`s
belief
that the company`s disclosure controls and procedures were
effective
during the relevant periods in light of the numerous significant
deficiencies identified by Ernst & Young. In your response,
please
address the consideration management gave to the nature and extent
of
the adjusting entries that you listed for us in your letter of
March
17, 2005. Among other things, we note that many of the adjusting
journal entries were made on a post-closing basis and were
identified
by Ernst & Young, not management. Also supplement your response
to
acknowledge the existence of the other significant deficiencies in
addition to the delays in the reporting process.
* * * *
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. Please furnish a
letter
that keys your response to our comment and provides any requested
supplemental information. Please file your response letter on
EDGAR.
You may contact Derek Swanson, Staff Attorney, at (202) 824-
5526, or me at (202) 942-1990 with any other questions.
Sincerely,
Michele M. Anderson
Legal Branch Chief
cc: Joo Ryu Kang
Dorsey & Whitney LLP
Via Facsimile: (949) 932-3601
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Iteris, Inc.
May 23, 2005
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