SEC Company Response from FAIR ISAAC CORP (FICO) (CIK 0000814547) (FICO) — Mar 10, 2005
FAIR ISAAC CORP (FICO) (CIK 0000814547)
Date: March 10, 2005 · CIK: 0000814547 · Accession: 0000950134-05-004641
AI Filing Summary & Sentiment
Letter
VIA EDGAR AND OVERNIGHT MAIL Office of Mergers and Acquisitions Securities and Exchange Commission Washington, D.C. 20549-0303 Re: Fair Isaac Corporation Schedule TO filed on February 25, 2005 File No. 005-39117
Dear Ms. Murphy:
We submit this letter in response to comments from the staff of the Securities and Exchange Commission (the “Commission”), received by letter, dated March 9, 2005, relating to Fair Isaac Corporation’s (the “Company”) offer to exchange (the “Exchange Offer”) up to $400,000,000 principal amount of its 1.5% Senior Convertible Notes, Series B due August 15, 2023 for any or all of the Company’s outstanding 1.5% Senior Convertible Notes due August 15, 2023, the Schedule TO-I, filed on February 25, 2005 (File No. 005-39117) (the “Schedule TO”), and the Offering Circular, dated February 25, 2005, filed as Exhibit (a)(1)(A) to the Schedule TO, relating to the Exchange Offer.
The Company hereby acknowledges the following:
• the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
• staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filings; and
• the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact John A. Fore or Kathleen D. Rothman of Wilson Sonsini Goodrich & Rosati, Professional Corporation, at (650) 493-9300 with any questions or with additional requests for information.
Very truly yours,
FAIR ISAAC CORPORATION
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[Fair Isaac Corporation Letterhead]
March 10, 2005
VIA EDGAR AND OVERNIGHT MAIL
Ms. Celeste M. Murphy
Office of Mergers and Acquisitions
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0303
Re:
Fair Isaac Corporation
Schedule TO filed on February 25, 2005
File No. 005-39117
Dear Ms. Murphy:
We submit this letter in response to comments from the staff of the Securities and Exchange
Commission (the “Commission”), received by letter, dated March 9, 2005, relating to Fair Isaac
Corporation’s (the “Company”) offer to exchange (the “Exchange Offer”) up to $400,000,000 principal
amount of its 1.5% Senior Convertible Notes, Series B due August 15, 2023 for any or all of the
Company’s outstanding 1.5% Senior Convertible Notes due August 15, 2023, the Schedule TO-I, filed
on February 25, 2005 (File No. 005-39117) (the “Schedule TO”), and the Offering Circular, dated
February 25, 2005, filed as Exhibit (a)(1)(A) to the Schedule TO, relating to the Exchange Offer.
The Company hereby acknowledges the following:
•
the Company is responsible for the adequacy and accuracy of the disclosure in the filings;
•
staff comments or changes to disclosure in response to staff comments in the filings
reviewed by the staff do not foreclose the Commission from taking any action with
respect to the filings; and
•
the Company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.
Please contact John A. Fore or Kathleen D. Rothman of Wilson Sonsini Goodrich & Rosati,
Professional Corporation, at (650) 493-9300 with any questions or with additional requests for
information.
Very truly yours,
FAIR ISAAC CORPORATION
/s/ Charles M. Osborne
Charles M. Osborne
Vice President and Chief Financial Officer
cc:
John A. Fore
Kathleen D. Rothman