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SEC Company Response from TOLLGRADE COMMUNICATIONS INC \PA\ (CIK 0001002531) — Dec 7, 2005

TOLLGRADE COMMUNICATIONS INC \PA\ (CIK 0001002531)
Date: Dec. 7, 2005 · CIK: 0001002531 · Accession: 0000950128-05-000200

AI Filing Summary & Sentiment

Date
December 7, 2005
Author
/s/Samuel C. Knoch
Form
CORRESP
Company
TOLLGRADE COMMUNICATIONS INC \PA\ (CIK 0001002531)

Letter

Securities and Exchange Commission Form 10-K for Fiscal Year Ended December 31, 2004 Filed on March 3, 2005 Form 10-Q for Fiscal Quarter Ended March 26, 2005 File No. 0-27312

Re:

Dear Mr. Spirgel,

This letter sets forth the responses of Tollgrade Communications, Inc. (the “Company”) to additional questions that were raised during our teleconference call on November 23, 2005.

I had indicated on our call that at each of our annual goodwill impairments test dates at December 31, 2002, 2003 and 2004 our quoted share price exceeded the calculated net book value. The staff had requested that I confirm this in writing. That detailed information is set forth below:

December 31,

Net Book Value

Quoted Share Price

$10.87

$11.73

$11.11

$17.53

$11.20

$12.24

In addition, the Staff requested that I confirm in writing that to date there have been no events that would more likely than not have reduced the fair value of the business below its carrying amount as discussed in paragraph 28 of SFAS No. 142.

The Company believes that the above explanations have been responsive to your requests. Should you need further information, please contact Sam Knoch at 412-820-1406.

Sincerely,
/s/Samuel C. Knoch

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CORRESP
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corresp

December 7, 2005

Larry Spirgel

Assistant Director

Securities and Exchange Commission

Washington D.C. 20549

    Re:

    Tollgrade Communications, Inc.

Form 10-K for Fiscal Year Ended December 31, 2004

Filed on March 3, 2005

Form 10-Q for Fiscal Quarter Ended March 26, 2005

File No. 0-27312

Dear Mr. Spirgel,

     This letter sets forth the responses of Tollgrade Communications, Inc. (the “Company”) to
additional questions that were raised during our teleconference call on November 23, 2005.

     I had indicated on our call that at each of our annual goodwill impairments test dates at
December 31, 2002, 2003 and 2004 our quoted share price exceeded the calculated net book value.
The staff had requested that I confirm this in writing. That detailed information is set forth
below:

    December 31,

    Net Book Value

    Quoted Share Price

    2002

    $10.87

    $11.73

    2003

    $11.11

    $17.53

    2004

    $11.20

    $12.24

     In addition, the Staff requested that I confirm in writing that to date there have been no
events that would more likely than not have reduced the fair value of the business below its
carrying amount as discussed in paragraph 28 of SFAS No. 142.

     The Company believes that the above explanations have been responsive to your requests.
Should you need further information, please contact Sam Knoch at 412-820-1406.

Sincerely,

/s/Samuel C. Knoch

Samuel C. Knoch

Chief Financial Officer