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SEC Company Response from HYPERION SOLUTIONS CORP (CIK 0001001113) — Aug 30, 2005

HYPERION SOLUTIONS CORP (CIK 0001001113)
Date: Aug. 30, 2005 · CIK: 0001001113 · Accession: 0000950172-05-002896

AI Filing Summary & Sentiment

Date
August 30, 2005
Author
/s/ Gregory C. Smith
Form
CORRESP
Company
HYPERION SOLUTIONS CORP (CIK 0001001113)

Letter

[SKADDEN LETTERHEAD] August 30, 2005 VIA EDGAR --------- Craig D. Wilson Division of Corporate Finance Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549

Re: Hyperion Solutions Corporation Forms 8-K filed on April 21, 2005, January 31, 2005, October 27, 2004 and July 21, 2004; and Form 10-Q for the quarter ended March 31, 2005, filed on May 10, 2005. File No. 0-26934

Dear Mr. Wilson:

Set forth below are Hyperion Solutions Corporation's (the "Company") responses to the comments raised in the Securities and Exchange Commission's (the "Commission") follow-up letter to the Company dated August 4, 2005 (the "Comment Letter"). For your convenience, we have numbered each of the Company's responses to correspond to the numbered comments in the Comment Letter. Additionally, the text of each of the numbered comments in the Comment Letter has been duplicated in bold type to precede each of the Company's responses.

1. With regard to your future disclosures surrounding auction rate securities we have the following comments:

a. Explain that the reason for the reclassification was to comply with SFAS No. 95. Please note that we do not agree with your characterization of the reclassification, in the Form 8-K filed on April 21, 2005, as being "based on the latest interpretation of cash equivalents."

<PAGE>

Mr. Craig D. Wilson Securities and Exchange Commission August 30, 2005 Page 2

Response --------

The Company will endeavor to explain that the reason for the reclassification was to comply with SFAS No. 95 in its future disclosures surrounding auction rate securities.

b. Justify the classification of these securities as current by describing how you determined that you have a reasonable expectation of completing a successful auction within the subsequent twelve-month period.

Response --------

The Company will endeavor to describe its determination that it has a reasonable expectation of completing a successful auction in its future disclosures surrounding auction rate securities.

Please feel free to call me at (650) 470-4590 should you have any further questions regarding this matter.

Sincerely,
/s/ Gregory C. Smith
--------------------
Gregory C. Smith

Show Raw Text
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                                                                   CONFIDENTIAL
                                                                   ------------

                              [SKADDEN LETTERHEAD]

                                                 August 30, 2005

VIA EDGAR
---------
Craig D. Wilson
Division of Corporate Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

         Re:    Hyperion Solutions Corporation
                Forms 8-K filed on April 21, 2005, January 31, 2005,
                October 27, 2004 and July 21, 2004; and Form 10-Q
                for the quarter ended March 31, 2005, filed on May
                10, 2005.
                File No. 0-26934

Dear Mr. Wilson:

         Set forth below are Hyperion Solutions Corporation's (the "Company")
responses to the comments raised in the Securities and Exchange Commission's
(the "Commission") follow-up letter to the Company dated August 4, 2005 (the
"Comment Letter"). For your convenience, we have numbered each of the Company's
responses to correspond to the numbered comments in the Comment Letter.
Additionally, the text of each of the numbered comments in the Comment Letter
has been duplicated in bold type to precede each of the Company's responses.

     1.   With regard to your future disclosures surrounding auction rate
          securities we have the following comments:

          a.   Explain that the reason for the reclassification was to comply
               with SFAS No. 95. Please note that we do not agree with your
               characterization of the reclassification, in the Form 8-K filed
               on April 21, 2005, as being "based on the latest interpretation
               of cash equivalents."

<PAGE>

Mr. Craig D. Wilson
Securities and Exchange Commission
August 30, 2005
Page 2

     Response
     --------

         The Company will endeavor to explain that the reason for the
reclassification was to comply with SFAS No. 95 in its future disclosures
surrounding auction rate securities.

          b.   Justify the classification of these securities as current by
               describing how you determined that you have a reasonable
               expectation of completing a successful auction within the
               subsequent twelve-month period.

     Response
     --------

         The Company will endeavor to describe its determination that it has a
reasonable expectation of completing a successful auction in its future
disclosures surrounding auction rate securities.

         Please feel free to call me at (650) 470-4590 should you have any
further questions regarding this matter.

                                          Sincerely,

                                          /s/ Gregory C. Smith
                                          --------------------
                                          Gregory C. Smith

cc:   Tamara Tangen, SEC
      Stephen Krikorian, SEC
      David W. Odell, Hyperion Solutions Corporation

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