SEC Comment Letter for Ernexa Therapeutics Inc. (ERNA, ERNAW) (CIK 0000748592) (ERNA) — Jan 28, 2008
Ernexa Therapeutics Inc. (ERNA, ERNAW) (CIK 0000748592)
Date: Jan. 28, 2008 · CIK: 0000748592 · Accession: 0000000000-08-004639
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-11460
Referenced dates: January 17, 2008, November 9, 2007
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3720 January 28, 2008 Via U.S. Mail and Fax (1-760-929-5280) Kendra Berger Chief Financial Officer NTN Buzztime, Inc. 5966 La Place Court Carlsbad, California, 92008 Re: NTN Buzztime, Inc. Form 10-K for Fiscal Year Ended December 31, 2006 Filed March 16, 2007 Forms 10-Q for Fiscal Quarter Ended September 30, 2007 File No. 001-11460
Dear Ms. Berger: We have reviewed your supplemental response letter dated January 17, 2008 as well as your filing and have the following comments. As noted in our comment letter dated November 9, 2007, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. Form 10-K for Fiscal Year Ended December 31, 2006
Note 1 – Organization and Summary of Significant Accounting Policies
Critical Accounting Policies and Estimates, page F-11
1. We note your response to prior comment 3. You should revise your accounting policy to comply with our prior comment. Accordingly:
• You appear to have up-front fees (i.e. deferred revenues) for some if not all of your customer contracts. When both costs and revenue (in an amount equal to or greater than the costs) are deferred for a specific contract, those capitalized costs should be charged to expense proportionally and over the same period that deferred revenue is recognized as revenue.
Ms. Kendra Berger NTN Buzztime, Inc. January 28, 2008 Page 2 • We note your statement that your deferred costs exceed your deferred revenues for your contractual arrangements. We also note that you can recover the deferred installation and commission costs during the initial contract term of each specific customer. For any excess of deferred costs over deferred revenues for a specific customer, you should revise to recognize those excess costs over the initial period of the contract which you have stated to be 1 year.
Form 10-Q for the Fiscal Quarters Ended September 30, 2007
(10) Accumulated Other Comprehensive Income (Loss), page 13
2. We note your response to prior comment 6. However, your attachment 3 appears to be incomplete. The impact of the foreign currency translation adjustment in the equity section is missing. Please advice.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. You may contact Inessa Kessman, Senior Staff Accountant, at (202) 551-3371 or Kyle Moffatt, Accountant Branch Chief, at (202) 551- 3836 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions.
S i n c e r e l y , L a r r y S p i r g e l A s s i s t a n t D i r e c t o r
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
January 28, 2008
Via U.S. Mail and Fax (1-760-929-5280)
Kendra Berger
Chief Financial Officer NTN Buzztime, Inc. 5966 La Place Court Carlsbad, California, 92008
Re: NTN Buzztime, Inc.
Form 10-K for Fiscal Year Ended December 31, 2006
Filed March 16, 2007
Forms 10-Q for Fiscal Quarter Ended September 30, 2007
File No. 001-11460
Dear Ms. Berger:
We have reviewed your supplemental response letter dated January 17, 2008 as
well as your filing and have the following comments. As noted in our comment letter dated November 9, 2007, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
Form 10-K for Fiscal Year Ended December 31, 2006
Note 1 – Organization and Summary of Significant Accounting Policies
Critical Accounting Policies and Estimates, page F-11
1. We note your response to prior comment 3. You should revise your accounting policy to comply with our prior comment. Accordingly:
• You appear to have up-front fees (i.e. deferred revenues) for some if not all of your customer contracts. When both costs and revenue (in an amount equal to or greater than the costs) are deferred for a specific contract, those capitalized costs should be charged to expense proportionally and over the same period that deferred revenue is recognized as revenue.
Ms. Kendra Berger
NTN Buzztime, Inc. January 28, 2008 Page 2
• We note your statement that your deferred costs exceed your deferred revenues for your contractual arrangements. We also note that you can recover the deferred installation and commission costs during the initial contract term of each specific customer. For any excess of deferred costs over deferred revenues for a specific customer, you should revise to recognize those excess costs over the initial period of the contract which you have stated to be 1 year.
Form 10-Q for the Fiscal Quarters Ended September 30, 2007
(10) Accumulated Other Comprehensive Income (Loss), page 13
2. We note your response to prior comment 6. However, your attachment 3 appears
to be incomplete. The impact of the foreign currency translation adjustment in the equity section is missing. Please advice.
* * * *
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. You may contact Inessa Kessman, Senior Staff Accountant, at (202) 551-3371 or Kyle Moffatt, Accountant Branch Chief, at (202) 551-
3836 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions.
S i n c e r e l y , L a r r y S p i r g e l A s s i s t a n t D i r e c t o r