SEC Comment Letter for QIAGEN NV (QGEN) (CIK 0001015820) (QGEN) — Oct 7, 2005
QIAGEN NV (QGEN) (CIK 0001015820)
Date: Oct. 7, 2005 · CIK: 0001015820 · Accession: 0000000000-05-051708
AI Filing Summary & Sentiment
File numbers found in text: 000-28564
Letter
Via Facsimile and U.S. Mail October 3, 2005 Mr. Roland Sackers Deputy Managing Director, Chief Financial Officer QIAGEN N.V. Spoorstraat 50 The Netherlands 011-31-77-320-8400
Re: QIAGEN N.V. Form 20-F for Fiscal Year Ended December 31, 2004 File No. 000-28564
Dear Mr. Sackers:
We have reviewed your August 22, 2005 response and have the following comments. In our comments, we ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Consolidated Financial Statements
Notes to Consolidated Financial Statements
4. Acquisitions and Disposals, page F-6
1. Please refer to your response to comment #2. Please provide us an explanation as to why you are unable to clearly distinguish the two businesses, either operationally or for financial reporting purposes.
6. Variable Interest Entities, page F-18
2. Please refer to your response to comment #3. Please expand your explanation to us as to why Qiagen N.V. is not the primary beneficiary of the Qiagen Finance (Luxembourg) S.A., a self proscribed variable interest entity. Please provide management`s assessment as to who is the primary beneficiary and the specific reasons or provisions of the structure which supports this assessment. Additionally, please address in response your compliance with paragraphs 2 and 3 of Accounting Research Bulletin No. 51 Consolidated Financial Statements.
9. Property, Plant and Equipment, page F-20 3. We have reviewed your response to comment #5, please tell us how you have complied with paragraph 16 of SFAS 140, Accounting for Transfers and Servicing of Financial Assets and Extinguishments of Liabilities, as it does not appear the you have paid the creditor and been relieved of your obligation nor legally released from being the primary obligor under the liability.
* * * *
Please respond to the comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides requested information. Detailed letters greatly facilitate our review. Please file your letter on EDGAR under the form type label CORRESP.
You may contact Todd Sherman, Staff Accountant, at 202-551- or Kevin Woody, Branch Chief, at 202-551-3629 if you have questions regarding the comment. In this regard, do not hesitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant
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<TYPE>LETTER
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<TEXT>
Mail Stop 6010
Via Facsimile and U.S. Mail
October 3, 2005
Mr. Roland Sackers
Deputy Managing Director,
Chief Financial Officer
QIAGEN N.V.
Spoorstraat 50
The Netherlands
011-31-77-320-8400
Re: QIAGEN N.V.
Form 20-F for Fiscal Year Ended December 31, 2004
File No. 000-28564
Dear Mr. Sackers:
We have reviewed your August 22, 2005 response and have the
following comments. In our comments, we ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Consolidated Financial Statements
Notes to Consolidated Financial Statements
4. Acquisitions and Disposals, page F-6
1. Please refer to your response to comment #2. Please provide us
an
explanation as to why you are unable to clearly distinguish the
two
businesses, either operationally or for financial reporting
purposes.
6. Variable Interest Entities, page F-18
2. Please refer to your response to comment #3. Please expand
your
explanation to us as to why Qiagen N.V. is not the primary
beneficiary of the Qiagen Finance (Luxembourg) S.A., a self
proscribed variable interest entity. Please provide
management`s
assessment as to who is the primary beneficiary and the specific
reasons or provisions of the structure which supports this
assessment. Additionally, please address in response your
compliance
with paragraphs 2 and 3 of Accounting Research Bulletin No. 51
Consolidated Financial Statements.
9. Property, Plant and Equipment, page F-20
3. We have reviewed your response to comment #5, please tell us
how
you have complied with paragraph 16 of SFAS 140, Accounting for
Transfers and Servicing of Financial Assets and Extinguishments of
Liabilities, as it does not appear the you have paid the creditor
and
been relieved of your obligation nor legally released from being
the
primary obligor under the liability.
* * * *
Please respond to the comment within 10 business days or
tell
us when you will provide us with a response. Please furnish a
letter
that keys your response to our comment and provides requested
information. Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.
You may contact Todd Sherman, Staff Accountant, at 202-551-
3665
or Kevin Woody, Branch Chief, at 202-551-3629 if you have
questions
regarding the comment. In this regard, do not hesitate to contact
me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant
??
??
??
??
Roland Sackers
QIAGEN N.V.
October 3, 2005
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