SEC Comment Letter for DIGI INTERNATIONAL INC (DGII) (CIK 0000854775) (DGII) — Apr 8, 2010
DIGI INTERNATIONAL INC (DGII) (CIK 0000854775)
Date: April 8, 2010 · CIK: 0000854775 · Accession: 0000000000-10-019290
AI Filing Summary & Sentiment
File numbers found in text: 001-34033
Referenced dates: February 12, 2010, March 9, 2010
Letter
Mail Stop 4561 A p r i l 8 , 2 0 1 0 Subramanian Krishnan Senior VP, CFO and Treasurer Digi International Inc. 11001 Bren Road East Minnetonka, Minnesota 55343 Re: Digi International Inc. Form 10-K for the Fiscal Year Ended September 30, 2009 Filed December 3, 2009 File No. 001-34033
Dear Mr. Krishnan: We have reviewed your response letter dated March 9, 2010 in connection with the above referenced filing and have the following comment. If indicated, we think you should revise your document in response to this comm ent. 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 our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may raise a dditional comments. Unless otherwise noted, where prior comments are referred to they re fer to our letter dated February 12, 2010.
Form 10-K for the Fiscal Year Ended September 30, 2009
Schedule II – Valuation and Qualifying Accounts, page 89 1. We note your response to prior comment 1. Please describe your accounting for sales of inventory for which you have established a reserve in further detail. As part of your response, please tell us how you ensure that your inventory re serve is reduced as sales of related inventory occur.
* * * * * * *
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your filing(s), you may wish to provide us with marked copies of a ny amendment to expedite our review. Please furnish a cover letter that keys your respons e to our comment and provides any requested information. Detailed cover lette rs greatly facilitate our revi ew. Please understand that we
Subramanian Krishnan Digi International Inc. April 8, 2010 Page 2 may have additional comments after reviewi ng any amendment and your response to our comment. You may contact David Edgar, Staff Accountant, at ( 202) 551-3459 if you have any questions regarding comments on the financial statements and related matters. Please address questions regarding a ll other comments to Katherine Wray, Attorney-Advisor, at (202) 551-3483 or Mark Shuman, Branch Ch ief-Legal, at (202) 551-3462. If you need further assistance, you may contact me at (202) 551-3226. S i n c e r e l y , C r a i g W i l s o n Sr. Asst. Chief Accountant
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Mail Stop 4561 A p r i l 8 , 2 0 1 0 Subramanian Krishnan Senior VP, CFO and Treasurer Digi International Inc. 11001 Bren Road East Minnetonka, Minnesota 55343
Re: Digi International Inc.
Form 10-K for the Fiscal Year Ended September 30, 2009
Filed December 3, 2009 File No. 001-34033
Dear Mr. Krishnan:
We have reviewed your response letter dated March 9, 2010 in connection with the
above referenced filing and have the following comment. If indicated, we think you should revise your document in response to this comm ent. 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 our comment, we may ask you to provide us
with supplemental information so we may better understand your disclosure. After
reviewing this information, we may raise a dditional comments. Unless otherwise noted,
where prior comments are referred to they re fer to our letter dated February 12, 2010.
Form 10-K for the Fiscal Year Ended September 30, 2009
Schedule II – Valuation and Qualifying Accounts, page 89
1. We note your response to prior comment 1. Please describe your accounting for sales
of inventory for which you have established a reserve in further detail. As part of
your response, please tell us how you ensure that your inventory re serve is reduced as
sales of related inventory occur.
* * * * * * *
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please submit all correspondence and supplemental materials on
EDGAR as required by Rule 101 of Regulation S-T. If you amend your filing(s), you may
wish to provide us with marked copies of a ny amendment to expedite our review. Please
furnish a cover letter that keys your respons e to our comment and provides any requested
information. Detailed cover lette rs greatly facilitate our revi ew. Please understand that we
Subramanian Krishnan
Digi International Inc. April 8, 2010 Page 2 may have additional comments after reviewi ng any amendment and your response to our
comment.
You may contact David Edgar, Staff Accountant, at ( 202) 551-3459 if you have any
questions regarding comments on the financial statements and related matters. Please
address questions regarding a ll other comments to Katherine Wray, Attorney-Advisor, at
(202) 551-3483 or Mark Shuman, Branch Ch ief-Legal, at (202) 551-3462. If you need
further assistance, you may contact me at (202) 551-3226.
S i n c e r e l y , C r a i g W i l s o n
Sr. Asst. Chief Accountant