SEC Company Response from VISUAL NETWORKS INC (CIK 0001000495) — Oct 14, 2004
VISUAL NETWORKS INC (CIK 0001000495)
Date: Oct. 14, 2004 · CIK: 0001000495 · Accession: 0001193125-04-171392
AI Filing Summary & Sentiment
File numbers found in text: 000-23699
Letter
VIA EDGAR Securities and Exchange Commission Washington, DC 20549 Re: Visual Networks, Inc. Form 8-K filed September 20, 2004 File No. 000-23699
Dear Ms. Walsh:
This firm represents Visual Networks, Inc. (the “Company”) and is writing in response to your letter of October 4, 2004. The Company filed the above mentioned Form 8-K disclosing that it had engaged new accountants. Item 304(a)(2) of Regulation S-K provides that if the Company had consulted with the new accountants during the two most recent fiscal years or subsequent interim period prior to their engagement, the Company would be required to disclose the details of such consultation. The Company never consulted with the new accountants prior to the engagement, and accordingly, the Company did not disclose the lack of such consultation. Thus, we respectfully submit that there is no revision necessary to the Company’s disclosure since the Form 8-K is accurate and adequate in light of the requirement of Item 304(a)(2).
Sincerely,
/s/ Nancy A. Spangler
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CORRESP 1 dcorresp.htm CORRESPONDENCE CORRESPONDENCE 1775 Wiehle Avenue, Suite 400 Reston, Virginia 20190-5159 main 703.773.4000 fax 703.773.5000 NANCY A. SPANGLER nancy.spangler@piperrudnick.com direct 703.773.4021 fax 703.773.5021 October 14, 2004 FACSIMILE AND U.S. MAIL VIA EDGAR Melissa Walsh Staff Accountant Securities and Exchange Commission 450 Washington, DC 20549 Re: Visual Networks, Inc. Form 8-K filed September 20, 2004 File No. 000-23699 Dear Ms. Walsh: This firm represents Visual Networks, Inc. (the “Company”) and is writing in response to your letter of October 4, 2004. The Company filed the above mentioned Form 8-K disclosing that it had engaged new accountants. Item 304(a)(2) of Regulation S-K provides that if the Company had consulted with the new accountants during the two most recent fiscal years or subsequent interim period prior to their engagement, the Company would be required to disclose the details of such consultation. The Company never consulted with the new accountants prior to the engagement, and accordingly, the Company did not disclose the lack of such consultation. Thus, we respectfully submit that there is no revision necessary to the Company’s disclosure since the Form 8-K is accurate and adequate in light of the requirement of Item 304(a)(2). Sincerely, /s/ Nancy A. Spangler Nancy A. Spangler /nas cc: Donald E. Clarke Piper Rudnick LLP