SEC Comment Letter for DATA I (DAIO) — Dec 22, 2017
DATA I/O CORP
Date: Dec. 22, 2017 · CIK: 0000351998 · Accession: 0000000000-17-044878
AI Filing Summary & Sentiment
File numbers found in text: 000-10394
Letter
Mail Stop 4628 December 21, 2017 Via E -mail Joel S. Hatlen Vice President, Chief Operating Officer, Chief Financial Officer , Secretary and Treasurer Data I/O Corporation 6645 185th Avenue Northeast Suite 100 Redmond, Washington 98052
Re: Data I/O Corporation 10-K for Fiscal Year Ended December 31, 2016 Filed March 28, 2017 File No. 000-10394
Dear Mr. Hatlen :
We have limited our review of your filing to your contacts with countries that have been identified as state sponsors of terrorism, and we have the following comment . Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. In our comment , we ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not beli eve our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
General
1. You state on page 6 of the 10 -K that Bosch accounted for approximat ely 11% of your 2016 net sales. We are aware of publicly available information stating that Bosch companies are serving North Korea, identifying a Bosch dealer in Sudan and indicating that Bosch has a regional headquarters in Dubai offering products and so lutions to customers in Syria.
North Korea, Sudan and Syria are designated by the U.S. Department of State as state sponsors of terrorism, and are subject to U.S. economic sanctions and/or export controls. Please describe to us the nature and extent of any past, current, and anticipated contacts with North Korea, Sudan and Syria, whether through subsidiaries, affiliates, distributors,
Joel S. Hatlen Data I/O Corporation December 21 , 2017 Page 2 partners, resellers, customers, joint ventures or other direct or indirect arrangements. You should describe any service s, products, information or technology you have provided to North Korea, Sudan or Syria, directly or indirectly, and any agreements, commercial arrangements, or other contacts you have had with the governments of those countries or entities they control.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Daniel Leslie, Staff Attorney, at (202) 551-3876 or me at (202) 551 - 3470 if you have any questions about the comment or our review.
Sincerely,
/s/ Cecilia Blye
Show Raw Text
Mail Stop 4628 December 21, 2017 Via E -mail Joel S. Hatlen Vice President, Chief Operating Officer, Chief Financial Officer , Secretary and Treasurer Data I/O Corporation 6645 185th Avenue Northeast Suite 100 Redmond, Washington 98052 Re: Data I/O Corporation 10-K for Fiscal Year Ended December 31, 2016 Filed March 28, 2017 File No. 000-10394 Dear Mr. Hatlen : We have limited our review of your filing to your contacts with countries that have been identified as state sponsors of terrorism, and we have the following comment . Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. In our comment , we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not beli eve our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. General 1. You state on page 6 of the 10 -K that Bosch accounted for approximat ely 11% of your 2016 net sales. We are aware of publicly available information stating that Bosch companies are serving North Korea, identifying a Bosch dealer in Sudan and indicating that Bosch has a regional headquarters in Dubai offering products and so lutions to customers in Syria. North Korea, Sudan and Syria are designated by the U.S. Department of State as state sponsors of terrorism, and are subject to U.S. economic sanctions and/or export controls. Please describe to us the nature and extent of any past, current, and anticipated contacts with North Korea, Sudan and Syria, whether through subsidiaries, affiliates, distributors, Joel S. Hatlen Data I/O Corporation December 21 , 2017 Page 2 partners, resellers, customers, joint ventures or other direct or indirect arrangements. You should describe any service s, products, information or technology you have provided to North Korea, Sudan or Syria, directly or indirectly, and any agreements, commercial arrangements, or other contacts you have had with the governments of those countries or entities they control. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Daniel Leslie, Staff Attorney, at (202) 551-3876 or me at (202) 551 - 3470 if you have any questions about the comment or our review. Sincerely, /s/ Cecilia Blye Cecilia Blye, Chief Office of Global Security Risk cc: Amanda Ravitz Assistant Director Division of Corporation Financ e Robert Quy Corporate Controller Data I/O Corporation