SEC Comment Letter for Peraso Inc. (PRSO) (CIK 0000890394) (PRSO) — Mar 9, 2009
Peraso Inc. (PRSO) (CIK 0000890394)
Date: March 9, 2009 · CIK: 0000890394 · Accession: 0000000000-09-012079
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-32929
Referenced dates: February 9, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549
DIVISION OF CORPORATION FINANCE
Mail Stop 3030 March 9, 2009
VIA U.S. MAIL AND FAX (408) 731-1893
James W. Sullivan Chief Financial Officer Mosys, Inc. 755 N. Mathilda Avenue, Suite 100 Sunnyvale, California 94085 Re: Mosys, Inc. Form 10-K for the year ended December 31, 2007 Filed March 17, 2008 File No. 000-32929 Dear Mr. Sullivan:
We have reviewed your letter dated February 9, 2009 and have the following comments. Where indicated, we think you should revise yo ur future documents 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 necess ary in your explanation. In some of our comments, we may ask you to pr ovide us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requir ements 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 fr ee to call us at the telephone numbers listed at th e end of this letter.
James W. Sullivan Mosys, Inc. March 9, 2009 Page 2 Form 10-K for the Year Ended December 31, 2007
Financial Statements, page 50
Note 1: The Company and Summary of Significant Accounting Policies, page 54
Revenue Recognition, page 56 Royalty, page 58
1. Please refer to our prior comment 2. With rega rds to license agreement D, please further explain to us the terms of the agreement including all payments that were made to you under the agreement, how you accounted for each and why. In light of your obligation to develop and obtain silicon qualific ation as part of this agreement, please specifically tell us how you determined it was appropriate to recognize any revenue up front. We refer you to SAB Topic 13.A.3.f., noting footnote 36, whic h states that “the Staff believes that the vendor activities associated with the up front fee even if considered a deliverable to be evaluated under EITF 00-21, will rarely prov ide value to the customer on a standalone basis. Specifically cite the GAAP literature upon wh ich you based your accounting.
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter 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 responses to our comments. You may contact Andri Boerman, Staff Acc ountant, at (202) 551- 3645 or me at (202) 551-3640 if you have any questions regarding these co mments. In this regard, do not hesitate to contact Angela Crane, Branch Chief, at (202) 551-3554. S i n c e r e l y , J u l i e S h e r m a n Reviewing Accountant
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3030
March 9, 2009
VIA U.S. MAIL AND FAX (408) 731-1893
James W. Sullivan Chief Financial Officer
Mosys, Inc.
755 N. Mathilda Avenue, Suite 100 Sunnyvale, California 94085
Re: Mosys, Inc.
Form 10-K for the year ended December 31, 2007
Filed March 17, 2008 File No. 000-32929
Dear Mr. Sullivan:
We have reviewed your letter dated February 9, 2009 and have the following comments.
Where indicated, we think you should revise yo ur future documents 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 necess ary in your explanation.
In some of our comments, we may ask you to pr ovide us with information so we may better
understand your disclosure. After reviewing th is information, we may raise additional
comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements 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 fr ee to call us at the
telephone numbers listed at th e end of this letter.
James W. Sullivan
Mosys, Inc. March 9, 2009 Page 2
Form 10-K for the Year Ended December 31, 2007
Financial Statements, page 50
Note 1: The Company and Summary of Significant Accounting Policies, page 54
Revenue Recognition, page 56
Royalty, page 58
1. Please refer to our prior comment 2. With rega rds to license agreement D, please further
explain to us the terms of the agreement including all payments that were made to you
under the agreement, how you accounted for each and why. In light of your obligation to
develop and obtain silicon qualific ation as part of this agreement, please specifically tell
us how you determined it was appropriate to recognize any revenue up front. We refer
you to SAB Topic 13.A.3.f., noting footnote 36, whic h states that “the Staff believes that
the vendor activities associated with the up front fee even if considered a deliverable to
be evaluated under EITF 00-21, will rarely prov ide value to the customer on a standalone
basis. Specifically cite the GAAP literature upon wh ich you based your accounting.
As appropriate, please respond to these comments within 10 business days or tell us when
you will provide us with a response. Please furnish a cover letter 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
responses to our comments.
You may contact Andri Boerman, Staff Acc ountant, at (202) 551- 3645 or me at (202)
551-3640 if you have any questions regarding these co mments. In this regard, do not hesitate to
contact Angela Crane, Branch Chief, at (202) 551-3554. S i n c e r e l y , J u l i e S h e r m a n Reviewing Accountant