SEC Comment Letter for ION NETWORKS INC (CIK 0000754813) — Jul 25, 2005
ION NETWORKS INC (CIK 0000754813)
Date: July 25, 2005 · CIK: 0000754813 · Accession: 0000000000-05-038013
AI Filing Summary & Sentiment
File numbers found in text: 333-124274
Referenced dates: July 5, 2005
Letter
Room 4561 Norman E. Corn Chief Executive Officer Ion Networks, Inc. 120 Corporate Blvd. South Plainfield, NJ 07080 Form 10-KSB for the fiscal year ended December 31, 2004, as amended Form 10-QSB for the fiscal quarter ended March 31, 2005, as amended File No. 0-13117
Re: Ion Networks, Inc. Amendment No. 2 to Registration Statement on Form SB-2 Filed July 12, 2005 File No. 333-124274
Dear Mr. Corn:
We have reviewed your filings and have the following additional comment. With respect to the comment your response should be provided as soon as possible and not later than August 8, 2005. Form 10-KSB/A for the fiscal year ended December 31, 2004 Note 2. Summary of Significant Accounting Policies Revenue Recognition 1. We note your response to comment 5 of our letter dated July 5, 2005. Based on your previous responses, your business discussion and your website, it appears that you sell PRIISM software as a stand- alone software package that would fall under the scope of SOP 97- 2. Confirm that you are accounting for PRIISM under SOP 97-2 and if not, how you determined that this software is incidental as defined in paragraph 2 of SOP 97-2. To the extent accounting for PRIISM software under SOP 97-2 is appropriate, revise your revenue recognition policy to describe each product and service, how you are accounting for each product and service (e.g. PRIISMS, devices, tokens) and the authoritative literature that supports your accounting. Your policy should specifically address the factors outlined in paragraph 8 of SOP 97-2. * * * * *
You may contact Melissa Rocha, staff accountant, at (202) 551- 3854 or Marc Thomas, senior staff accountant at (202) 551-3452 if you have questions regarding comments on the financial statements and related matters. Please call Adam Halper at (202) 551-3482 or Sara Kalin at (202) 551-3454 with any other questions. If you need further assistance, you may contact me at (202) 551-3730.
Sincerely,
Barbara C. Jacobs
Assistant Director
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<FILENAME>filename1.txt
<TEXT>
July 25, 2005
Room 4561
Norman E. Corn
Chief Executive Officer
Ion Networks, Inc.
120 Corporate Blvd.
South Plainfield, NJ 07080
Re: Ion Networks, Inc.
Amendment No. 2 to Registration Statement on Form SB-2
Filed July 12, 2005
File No. 333-124274
Form 10-KSB for the fiscal year ended December 31, 2004, as
amended
Form 10-QSB for the fiscal quarter ended March 31, 2005, as
amended
File No. 0-13117
Dear Mr. Corn:
We have reviewed your filings and have the following
additional
comment. With respect to the comment your response should be
provided as soon as possible and not later than August 8, 2005.
Form 10-KSB/A for the fiscal year ended December 31, 2004
Note 2. Summary of Significant Accounting Policies
Revenue Recognition
1. We note your response to comment 5 of our letter dated July 5,
2005. Based on your previous responses, your business discussion
and
your website, it appears that you sell PRIISM software as a stand-
alone software package that would fall under the scope of SOP 97-
2.
Confirm that you are accounting for PRIISM under SOP 97-2 and if
not,
how you determined that this software is incidental as defined in
paragraph 2 of SOP 97-2. To the extent accounting for PRIISM
software under SOP 97-2 is appropriate, revise your revenue
recognition policy to describe each product and service, how you
are
accounting for each product and service (e.g. PRIISMS, devices,
tokens) and the authoritative literature that supports your
accounting. Your policy should specifically address the factors
outlined in paragraph 8 of SOP 97-2.
* * * * *
You may contact Melissa Rocha, staff accountant, at (202)
551-
3854 or Marc Thomas, senior staff accountant at (202) 551-3452 if
you
have questions regarding comments on the financial statements and
related matters. Please call Adam Halper at (202) 551-3482 or
Sara
Kalin at (202) 551-3454 with any other questions. If you need
further assistance, you may contact me at (202) 551-3730.
Sincerely,
Barbara C. Jacobs
Assistant Director
cc: Via Facsimile
James Alterbaum
Moses & Singer LLP
1301 Avenue of the Americas
New York, New York 10019
Phone: (212) 554-7800
Fax: (917) 206-4394
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Norman E. Corn
Ion Networks, Inc.
July 25, 2005
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