SEC Comment Letter for PLX TECHNOLOGY INC (CIK 0000850579) — Jun 27, 2005
PLX TECHNOLOGY INC (CIK 0000850579)
Date: June 27, 2005 · CIK: 0000850579 · Accession: 0000000000-05-032652
AI Filing Summary & Sentiment
Letter
June 27, 2005 Via Facsimile and U.S. Mail Mr. Rafael Torres Chief Financial Officer PLX Technology, Inc. 870 Maude Avenue Sunnyvale, CA 94085
Re: PLX Technology, Inc. Item 4.01 Form 8-K Filed June 23, 2005 File No. 0-25699
Dear Mr. Torres:
We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with more information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review 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 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 dated June 21, 2005
Item 4-01. Changes in Registrant`s Certifying Accountant
1. Please amend your Form 8-K to specifically state whether your former auditor resigned, declined to stand for re-election, or was dismissed. It is not sufficient to state that the company "chose not to extend the engagement" of the accountant, as that wording is unclear to a reader. Also, indicate whether the decision to change auditors was recommended or approved by your board of directors.
2. To the extent that you amend the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountant stating whether the accountant agrees with your Item 304 disclosures, or the extent to which the accountant does not agree.
* * * *
As appropriate, please amend your filing and respond to these comments within five business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your 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 your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the disclosure in the filing;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
If you have any questions, please call David Burton at (202) 551-3626.
Sincerely,
David Burton
Staff Accountant
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Mail Stop 6010
June 27, 2005
Via Facsimile and U.S. Mail
Mr. Rafael Torres
Chief Financial Officer
PLX Technology, Inc.
870 Maude Avenue
Sunnyvale, CA 94085
Re: PLX Technology, Inc.
Item 4.01 Form 8-K
Filed June 23, 2005
File No. 0-25699
Dear Mr. Torres:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with more
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our review 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 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 dated June 21, 2005
Item 4-01. Changes in Registrant`s Certifying Accountant
1. Please amend your Form 8-K to specifically state whether your
former auditor resigned, declined to stand for re-election, or was
dismissed. It is not sufficient to state that the company "chose
not
to extend the engagement" of the accountant, as that wording is
unclear to a reader. Also, indicate whether the decision to
change
auditors was recommended or approved by your board of directors.
2. To the extent that you amend the Form 8-K to comply with our
comments, please obtain and file an updated Exhibit 16 letter from
the former accountant stating whether the accountant agrees with
your
Item 304 disclosures, or the extent to which the accountant does
not
agree.
* * * *
As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
provide
us with a response. You may wish to provide us with marked copies
of
the amendment to expedite our review. Please furnish a cover
letter
with your 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 your amendment and responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
If you have any questions, please call David Burton at (202)
551-3626.
Sincerely,
David Burton
Staff Accountant
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Mr. Rafael Torres
PLX Technology, Inc.
June 27, 2005
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