SEC Comment Letter for QUANTUM (QMCO) — Nov 14, 2007
QUANTUM CORP /DE/ (QMCO) (CIK 0000709283)
Date: Nov. 14, 2007 · CIK: 0000709283 · Accession: 0000000000-07-055757
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13449
Referenced dates: August 31, 2007
Letter
November 2, 2007 Room 4561 Mr. Jon Gacek Executive Vice President, Finance and Chief Financial Officer Quantum Corporation 11431 Willows Road Redmund, WA 98052
Re: Quantum Corporation Form 10-K for Fiscal Ye ar Ended March 31, 2006 Filed June 12, 2006 File No. 001-13449
Dear Mr. Gacek:
We have reviewed your response to our letter dated August 31, 2007 in connection with the above referenced fili ng and have the following comment.
Please understand that the purpose of our re view 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 comment or 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 Fiscal Year Ended March 31, 2006
Consolidated Financial Statements
Consolidated Statements of Operations, page 50 We note your response to prior comme nt 1 where you conclude that a reclassification of the StorageTek legal settl ement charge to operating expenses is not material. Considering that the reclassi fication would nearly double your operating loss for the fiscal year ended March 31, 2006, the Staf f is not in a position to concur with your conclusion. Please amend Form 10-K for th e fiscal year ended March 31, 2007 to include the StorageTek legal settlement expense in loss from operations both in Selected Financial Data and the audited financial statements. Management’s Discussion and Analysis should be accordingly revised to re flect the restated financial statements.
* * * * * * *
Mr. Jon Gacek Quantum Corporation November 2, 2007 Page 2 As appropriate, please amend your filing and respond to this comment within 10 business days or tell us when you will provi de us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. You may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cove r letter with any amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing any amendment and your responses to our comment.
You may contact David E dgar, Staff Accountant, at (202) 551-3459 or the undersigned at (202) 551-3730 if you have any questions regarding this comment.
Sincerely,
Craig Wilson
Senior Assistant Chief Accountant
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November 2, 2007 Room 4561 Mr. Jon Gacek Executive Vice President, Finance and Chief Financial Officer Quantum Corporation 11431 Willows Road Redmund, WA 98052 Re: Quantum Corporation Form 10-K for Fiscal Ye ar Ended March 31, 2006 Filed June 12, 2006 File No. 001-13449 Dear Mr. Gacek: We have reviewed your response to our letter dated August 31, 2007 in connection with the above referenced fili ng and have the following comment. Please understand that the purpose of our re view 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 comment or 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 Fiscal Year Ended March 31, 2006 Consolidated Financial Statements Consolidated Statements of Operations, page 50 We note your response to prior comme nt 1 where you conclude that a reclassification of the StorageTek legal settl ement charge to operating expenses is not material. Considering that the reclassi fication would nearly double your operating loss for the fiscal year ended March 31, 2006, the Staf f is not in a position to concur with your conclusion. Please amend Form 10-K for th e fiscal year ended March 31, 2007 to include the StorageTek legal settlement expense in loss from operations both in Selected Financial Data and the audited financial statements. Management’s Discussion and Analysis should be accordingly revised to re flect the restated financial statements. * * * * * * * Mr. Jon Gacek Quantum Corporation November 2, 2007 Page 2 As appropriate, please amend your filing and respond to this comment within 10 business days or tell us when you will provi de us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. You may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cove r letter with any amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing any amendment and your responses to our comment. You may contact David E dgar, Staff Accountant, at (202) 551-3459 or the undersigned at (202) 551-3730 if you have any questions regarding this comment. Sincerely, Craig Wilson Senior Assistant Chief Accountant