SEC Comment Letter for DESWELL INDUSTRIES INC (DSWL) (CIK 0000946936) (DSWL) — Mar 2, 2010
DESWELL INDUSTRIES INC (DSWL) (CIK 0000946936)
Date: March 2, 2010 · CIK: 0000946936 · Accession: 0000000000-10-011651
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33900
Referenced dates: January 13, 2010, January 28, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631
DIVISION OF CORPORATION FINANCE
Mail Stop 4631 February 22, 2010
via U.S. mail and facsimile
Betty Lam, Chief Financial Officer, Deswell Industries, Inc. 17B, Edificio Comercial Rodrigues, 599 Avenida da Praia Grande, Macao Special Administrative Region, PRC RE: Deswell Industries, Inc. Form 20-F for the Fiscal Year Ended March 31, 2009 Filed August 14, 2009 File No. 001-33900 Dear Ms. Lam:
We have reviewed your response letter dated January 28, 2010 and have the following additional comments. If you disagree , we will consider your explanation as to why our comment is inapplicable. Form 20-F for the Fiscal Year Ended March 31, 2009
Note 2 – Summary of Significant Accounting Policies, page F-6
Foreign Currency Tr anslation, page F-8
1. We note your response to prior comment 1 from our letter dated January 13, 2010 and have the following additional comments.
• Based on your response, it appears that you had a si gnificant amount of US dollar sales and US dollar expenses during the year ended March 31, 2008. As such, please provide us with a simila r analysis of each of the salient factors set forth in Appendix A of SFAS 52 to support th e use of the Hong Kong dollar and Chinese renmimbi as your f unctional currencies for the year ended March 31, 2008. Please ensure that your analysis addr esses the per centage of total US denominated sales that were generated by your Macao subsidiaries. • Please provide us with your proposed di sclosures to address in Management’s Discussion and Analysis the actual and reasonably likely effects of the change
Betty Lam, Chief Financial Officer Deswell Industries, Inc. February 22, 2010 Page 2 in your functional currenc y, including its impact on your results of operations, liquidity and cash flows.
* * * *
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may ha ve additional comments after reviewing responses to our comments. You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her absence Jeanne Baker at (202) 551-3691 or th e undersigned Accounting Branch Chief at (202) 551-3355 if you have questions regard ing comments on the financial statements and related matters. Please c ontact Hagen Ganem, Staff A ttorney, at (202) 551-3330 or Dieter King, Staff Attorney, at (202) 551-3338 with any legal related questions.
Sincerely,
T e r e n c e O ’ B r i e n A c c o u n t i n g B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
Mail Stop 4631
February 22, 2010
via U.S. mail and facsimile
Betty Lam, Chief Financial Officer, Deswell Industries, Inc. 17B, Edificio Comercial Rodrigues, 599 Avenida da Praia Grande, Macao Special Administrative Region, PRC
RE: Deswell Industries, Inc.
Form 20-F for the Fiscal Year Ended March 31, 2009
Filed August 14, 2009 File No. 001-33900
Dear Ms. Lam:
We have reviewed your response letter dated January 28, 2010 and have the
following additional comments. If you disagree , we will consider your explanation as to
why our comment is inapplicable. Form 20-F for the Fiscal Year Ended March 31, 2009
Note 2 – Summary of Significant Accounting Policies, page F-6
Foreign Currency Tr anslation, page F-8
1. We note your response to prior comment 1 from our letter dated January 13, 2010
and have the following additional comments.
• Based on your response, it appears that you had a si gnificant amount of US
dollar sales and US dollar expenses during the year ended March 31, 2008.
As such, please provide us with a simila r analysis of each of the salient factors
set forth in Appendix A of SFAS 52 to support th e use of the Hong Kong
dollar and Chinese renmimbi as your f unctional currencies for the year ended
March 31, 2008. Please ensure that your analysis addr esses the per centage of
total US denominated sales that were generated by your Macao subsidiaries.
• Please provide us with your proposed di sclosures to address in Management’s
Discussion and Analysis the actual and reasonably likely effects of the change
Betty Lam, Chief Financial Officer
Deswell Industries, Inc. February 22, 2010 Page 2
in your functional currenc y, including its impact on your results of operations,
liquidity and cash flows.
* * * *
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Please furnish a letter that keys your
responses to our comments and provides any requested supplemental information.
Detailed response letters greatly facilitate our review. Please file your response letter on
EDGAR. Please understand that we may ha ve additional comments after reviewing
responses to our comments. You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her
absence Jeanne Baker at (202) 551-3691 or th e undersigned Accounting Branch Chief at
(202) 551-3355 if you have questions regard ing comments on the financial statements
and related matters. Please c ontact Hagen Ganem, Staff A ttorney, at (202) 551-3330 or
Dieter King, Staff Attorney, at (202) 551-3338 with any legal related questions.
Sincerely,
T e r e n c e O ’ B r i e n A c c o u n t i n g B r a n c h C h i e f