SEC Company Response from ATTUNITY LTD (CIK 0000893821) — Sep 2, 2005
ATTUNITY LTD (CIK 0000893821)
Date: Sept. 2, 2005 · CIK: 0000893821 · Accession: 0000910662-05-000483
AI Filing Summary & Sentiment
File numbers found in text: 333-119157, 333-122937
Letter
VIA EDGAR --------- Ms. Barbara C. Jacobs Assistant Director Mr. Brad Skinner Branch Chief - Accounting Division of Corporation Finance Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549 Amendment No.1 to Form 20-F Annual Report For the Period Ended December 31, 2003 Filed on November 22, 2004 File No. 0-20892 ----------------
Re: Attunity Ltd Amendment No. 4 to Form F-3 filed April 20, 2005 File No. 333-119157 -------------------
Dear Ms. Jacobs and Mr. Skinner:
On behalf of our client, Attunity Ltd (the "Company"), we are submitting this letter in connection with our continuing dialog with respect to Amendment No. 4 to the Registration Statement on Form F-3 filed with the Securities and Exchange Commission on behalf of the Company on April 20, 2005. We await the Staff's response to this letter before filing the amendments to the above referenced Registration Statement and to the Company's other pending Registration Statement on Form F-3 ( File No. 333-122937).
Based on the recent conversation between Kenneth Marceron of the Company's independent auditors, Ernst & Young, and Joel Levine of the SEC Staff, the Company believes that it has demonstrated with compelling evidence that diverse industry practices exists with
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regard to methods used to calculate straight-line amortization of capitalized software development costs. The existence of such diversity can be found in the book entitled "Software Industry Accounting" by Joseph Morris and others as well as an informal survey of what other Big 4 firms see in practice that was performed by Ernst & Young.
Assuming that this accounting issue has been resolved, we believe that all of the outstanding comments have been responded Accordingly, we anticipate that the Company will file amendments to both of its registration statements next week. Please confirm that our understanding is correct.
Please do not hesitate to contact me at (212) 238-8605 with any questions or comments you may have.
Very truly yours,
/s/Steven J. Glusband
Steven J. Glusband
Show Raw Text
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CARTER LEDYARD & MILBURN LLP
Counselors at Law
2 Wall Street
570 Lexington Avenue New York, NY 10005-2072 1401 Eye Street, N.W.
New York, NY 10022 o Washington, DC 20005
(212) 371-2720 Tel (212) 732-3200 (202) 898-1515
Fax (212) 732-3232
September 2, 2005
VIA EDGAR
---------
Ms. Barbara C. Jacobs
Assistant Director
Mr. Brad Skinner
Branch Chief - Accounting
Division of Corporation Finance
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Re: Attunity Ltd
Amendment No. 4 to Form F-3
filed April 20, 2005
File No. 333-119157
-------------------
Amendment No.1 to Form 20-F
Annual Report For the Period Ended
December 31, 2003 Filed on
November 22, 2004
File No. 0-20892
----------------
Dear Ms. Jacobs and Mr. Skinner:
On behalf of our client, Attunity Ltd (the "Company"), we are submitting
this letter in connection with our continuing dialog with respect to Amendment
No. 4 to the Registration Statement on Form F-3 filed with the Securities and
Exchange Commission on behalf of the Company on April 20, 2005. We await the
Staff's response to this letter before filing the amendments to the above
referenced Registration Statement and to the Company's other pending
Registration Statement on Form F-3 ( File No. 333-122937).
Based on the recent conversation between Kenneth Marceron of the
Company's independent auditors, Ernst & Young, and Joel Levine of the SEC Staff,
the Company believes that it has demonstrated with compelling evidence that
diverse industry practices exists with
<PAGE>
2
regard to methods used to calculate straight-line amortization of capitalized
software development costs. The existence of such diversity can be found in the
book entitled "Software Industry Accounting" by Joseph Morris and others as well
as an informal survey of what other Big 4 firms see in practice that was
performed by Ernst & Young.
Assuming that this accounting issue has been resolved, we believe that
all of the outstanding comments have been responded Accordingly, we anticipate
that the Company will file amendments to both of its registration statements
next week. Please confirm that our understanding is correct.
Please do not hesitate to contact me at (212) 238-8605 with any
questions or comments you may have.
Very truly yours,
/s/Steven J. Glusband
Steven J. Glusband
SJG:tco
Enclosures
cc: Ofer Segev, Chief Financial Officer, Attunity Ltd
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