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SEC Comment Letter for ARTISOFT INC (CIK 0000877931) — May 16, 2005

ARTISOFT INC (CIK 0000877931)
Date: May 16, 2005 · CIK: 0000877931 · Accession: 0000000000-05-023962

AI Filing Summary & Sentiment

Date
May 16, 2005
Author
Patrick Gilmore, CPA
Form
UPLOAD
Company
ARTISOFT INC (CIK 0000877931)

Letter

May 16, 2005 Mail Stop: 4-6 Mr. Duncan Perry Chief Financial Officer Artisoft, Inc. 5 Cambridge Center Cambridge, MA 02142

Re: Item 4 Form 8-K filed April 27, 2005

Dear Mr. Perry:

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 supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. 1. We note in your 8-K that KPMG has advised management that in connection with the review of your three month period ended December 31, 2004, KPMG noted certain matters considered to constitute material weaknesses. Supplementally provide us with any written correspondence between management, the audit committee, KPMG and any others related to these material weaknesses.

2. Additionally, tell us whether any adjusting entries were made as a result of these material weaknesses and tell us in detail the steps you have taken (or plan to take) and procedures you implemented (or plan to implement) to correct these material weaknesses.

General

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed 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 comment, 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.

Please file your supplemental response and amendment via EDGAR in response to these comments within 5 business days of the date of this letter. Please note that if you require longer than 5 business days to respond, you should contact the staff immediately to request additional time. Any questions regarding the above should be directed to me at (202) 551-3406, or in my absence, to Robert Benton at (202) 551-3140.

Sincerely,
Patrick Gilmore, CPA
Staff Accountant
??

Show Raw Text
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<TEXT>

May 16, 2005

Mail Stop:  4-6

Mr. Duncan Perry
Chief Financial Officer
Artisoft, Inc.
5 Cambridge Center
Cambridge, MA 02142

Re:	Item 4 Form 8-K filed April 27, 2005

Dear Mr. Perry:

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 supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not 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 on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.
1. We note in your 8-K that KPMG has advised management that in
connection with the review of your three month period ended
December
31, 2004, KPMG noted certain matters considered to constitute
material weaknesses.  Supplementally provide us with any written
correspondence between management, the audit committee, KPMG and
any
others related to these material weaknesses.

2. Additionally, tell us whether any adjusting entries were made
as a
result of these material weaknesses and tell us in detail the
steps
you have taken (or plan to take) and procedures you implemented
(or
plan to implement) to correct these material weaknesses.

General

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filing reviewed by the staff to be
certain
that they have provided all information investors require for an
informed 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 comment, 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.

Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date of
this
letter.  Please note that if you require longer than 5 business
days
to respond, you should contact the staff immediately to request
additional time.  Any questions regarding the above should be
directed to me at (202) 551-3406, or in my absence, to Robert
Benton
at (202) 551-3140.

Sincerely,

Patrick Gilmore, CPA
Staff Accountant
??

??

??

??

Duncan Perry
Artisoft, Inc.
Page 1 of 2

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