SEC Comment Letter for AMTECH SYSTEMS INC (ASYS) (CIK 0000720500) (ASYS) — Jul 2, 2009
AMTECH SYSTEMS INC (ASYS) (CIK 0000720500)
Date: July 2, 2009 · CIK: 0000720500 · Accession: 0000000000-09-035279
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-11412
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE MAIL STOP 3030 July 2, 2009 Bradley C. Anderson Vice President – Finance and Chief Financial Officer Amtech Systems, Inc. 131 South Clark Drive Tempe, Arizona 85281 Re: Amtech Systems, Inc. Form 10-K for the fiscal ye ar ended September 30, 2008 Filed December 10, 2008 Form 8-K/A filed June 5, 2009 File No. 000-11412
Dear Mr. Anderson:
We have reviewed your response dated July 1, 2009 and related filings and have the following comments. Where indicated, we think you should revise your documents in response to these comments. If you disagr ee, we will consider your explanation as to why our comment is inapplicable or a revisi on is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Af ter reviewing this information, we may raise additional comments. 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 comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 8-K/A filed June 5, 2009
1. We refer to your response to our prio r comment number 4. As previously requested, please tell us how you have complied with Rules 3-01, 3-02, 3-05 and Article 10 of Regulation S-X with regard to the interim financial statements of the acquired entity. Please tell us where you have provided the financial statements and footnote disclosures required by Rule 10-01(a). The footnote disclosure should also include management’s standa rd representation on interim financial statements as required by Rule 10-01(b)(8) of Regulation S-X.
Bradley C. Anderson Amtech Systems, Inc. July 2, 2009 Page 2 2. We note your response to comment numb ers 6 and 7. Please note that these comments remain open until you have filed an amendment to the Form 8-K with the requested changes. Please tell us when you will amend the Form 8-K as indicated in your response.
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your response that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please submit your cover letter on EDGAR. Pleas e understand that we may ha ve additional comments after reviewing your responses to our comments. You may contact Jeanne Bennett, Staff Accountant, at (202) 551-3606 or me at (202) 551-3676 if you have questions regard ing comments on the financial statements and related matters. Please contact Celia So ehner, Staff Attorney, at (202) 551-3463 or Mary Beth Breslin, Senior Attorney, at (202) 551-3625 with any other questions.
S i n c e r e l y ,
Brian Cascio Accounting Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
MAIL STOP 3030
July 2, 2009
Bradley C. Anderson Vice President – Finance and Chief Financial Officer Amtech Systems, Inc. 131 South Clark Drive Tempe, Arizona 85281
Re: Amtech Systems, Inc.
Form 10-K for the fiscal ye ar ended September 30, 2008
Filed December 10, 2008 Form 8-K/A filed June 5, 2009 File No. 000-11412
Dear Mr. Anderson:
We have reviewed your response dated July 1, 2009 and related filings and have
the following comments. Where indicated, we think you should revise your documents
in response to these comments. If you disagr ee, we will consider your explanation as to
why our comment is inapplicable or a revisi on is unnecessary. Please be as detailed as
necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Af ter reviewing this
information, we may raise additional comments.
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 comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 8-K/A filed June 5, 2009
1. We refer to your response to our prio r comment number 4. As previously
requested, please tell us how you have complied with Rules 3-01, 3-02, 3-05 and
Article 10 of Regulation S-X with regard to the interim financial statements of the
acquired entity. Please tell us where you have provided the financial statements
and footnote disclosures required by Rule 10-01(a). The footnote disclosure
should also include management’s standa rd representation on interim financial
statements as required by Rule 10-01(b)(8) of Regulation S-X.
Bradley C. Anderson
Amtech Systems, Inc. July 2, 2009 Page 2 2. We note your response to comment numb ers 6 and 7. Please note that these
comments remain open until you have filed an amendment to the Form 8-K with the requested changes. Please tell us when you will amend the Form 8-K as indicated in your response.
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Please furnish a cover letter with your
response that keys your responses to our comments and provides any requested
information. Detailed cover letters greatly facilitate our review. Please submit your
cover letter on EDGAR. Pleas e understand that we may ha ve additional comments after
reviewing your responses to our comments.
You may contact Jeanne Bennett, Staff Accountant, at (202) 551-3606 or me at
(202) 551-3676 if you have questions regard ing comments on the financial statements
and related matters. Please contact Celia So ehner, Staff Attorney, at (202) 551-3463 or
Mary Beth Breslin, Senior Attorney, at (202) 551-3625 with any other questions.
S i n c e r e l y ,
Brian Cascio
Accounting Branch Chief