SEC Company Response from SIEBEL SYSTEMS INC (CIK 0001006835) — Nov 17, 2004
SIEBEL SYSTEMS INC (CIK 0001006835)
Date: Nov. 17, 2004 · CIK: 0001006835 · Accession: 0001006835-04-000044
AI Filing Summary & Sentiment
File numbers found in text: 333-68041, 333-91777
Referenced dates: September 20, 2004
Letter
United States Securities and Exchange Commission Division of Corporation Finance Re: Siebel Systems, Inc. (the "Company") Post-effective amendments on Forms S-3 Filed August 24, 2004 File Nos. 333-68041 and 333-91777
Dear Ms. Jacobs:
In response to the letter received by the Company from the Staff of the Securities and Exchange Commission (the "Commission") dated September 20, 2004, the Company hereby acknowledges that:
(i) should the Commission or the Staff, acting pursuant to delegated authority, declare the above referenced post-effective amendments on Form S-3 (the "Filings") effective, the Company does not foreclose the Commission from taking any action with respect to the Filings;
(ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Filings effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Filings; and
(iii) the Company will not assert the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Filings effective, as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If you should have any questions or comments, please do not hesitate to contact me at (650) 477-5662.
Very truly yours,
/s/ Jeffrey T. Amann
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CORRESP 1 filename1.htm November 3, 2004 Via Facsimile and Mail (202) 942-9544 Barbara Jacobs Assistant Director United States Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549-0406 Re: Siebel Systems, Inc. (the "Company") Post-effective amendments on Forms S-3 Filed August 24, 2004 File Nos. 333-68041 and 333-91777 Dear Ms. Jacobs: In response to the letter received by the Company from the Staff of the Securities and Exchange Commission (the "Commission") dated September 20, 2004, the Company hereby acknowledges that: (i) should the Commission or the Staff, acting pursuant to delegated authority, declare the above referenced post-effective amendments on Form S-3 (the "Filings") effective, the Company does not foreclose the Commission from taking any action with respect to the Filings; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Filings effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Filings; and (iii) the Company will not assert the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Filings effective, as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. If you should have any questions or comments, please do not hesitate to contact me at (650) 477-5662. Very truly yours, /s/ Jeffrey T. Amann Jeffrey T. Amann Senior Vice President and General Counsel cc: Sara Kalin, Securities and Exchange Commission J. Michael Lawrie Eric C. Jensen, Esq.