SEC Comment Letter for ALTAIR NANOTECHNOLOGIES INC (CIK 0001016546) — Aug 19, 2005
ALTAIR NANOTECHNOLOGIES INC (CIK 0001016546)
Date: Aug. 19, 2005 · CIK: 0001016546 · Accession: 0000000000-05-043042
AI Filing Summary & Sentiment
Letter
Mail Stop 7010 August 19, 2005 Mr. Alan J. Gotcher Chief Executive Officer Altair Nanotechnologies, Inc. 204 Edison Way Reno, Nevada 89502-2306
RE: Forms 10-K and 10-K/A for Fiscal Year Ended December 31, Forms 10-Q for Fiscal Quarters Ended March 31 and June 30, File No. 1-12497
Dear Mr. Gotcher:
We have reviewed your filings and have the following comments. If you disagree with a comment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-Q for the Quarter Ended March 31, 2005
General 1. Where a comment below requests additional disclosures or other revisions please show us in your supplemental response what the revisions will look like. These revisions should be included in your future filings, including your interim filings where applicable.
Note 2 - Summary of Significant Accounting Policies, page 7
Revenue Recognition, page 9 2. We have reviewed your response to comment eight. Despite the requirement that Spectrum reimburse you for the costs of fulfilling your obligation to employ commercially reasonable efforts to assist Spectrum in pre-clinical development, the obligation raises the question of whether, in the absence of your continuing involvement, Spectrum would have paid the amounts you have recognized as upfront revenues. It is unclear why this obligation, combined with the requirement that you attend regular meetings of the Joint Development Committee, is not analogous to that described in the second bullet point in the Facts of question one in SAB Topic 13:A3(f). Please advise.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review.
You may contact Scott Watkinson, Staff Accountant, at (202) 551-3741, or in his absence, me at (202) 551-3769 with any other questions.
Sincerely,
Rufus Decker
Accounting Branch Chief
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<TEXT>
Mail Stop 7010
August 19, 2005
Mr. Alan J. Gotcher
Chief Executive Officer
Altair Nanotechnologies, Inc.
204 Edison Way
Reno, Nevada 89502-2306
RE: Forms 10-K and 10-K/A for Fiscal Year Ended December 31,
2004
Forms 10-Q for Fiscal Quarters Ended March 31 and June
30,
2005
File No. 1-12497
Dear Mr. Gotcher:
We have reviewed your filings and have the following
comments. If you disagree with a comment, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-Q for the Quarter Ended March 31, 2005
General
1. Where a comment below requests additional disclosures or other
revisions please show us in your supplemental response what the
revisions will look like. These revisions should be included in
your
future filings, including your interim filings where applicable.
Note 2 - Summary of Significant Accounting Policies, page 7
Revenue Recognition, page 9
2. We have reviewed your response to comment eight. Despite the
requirement that Spectrum reimburse you for the costs of
fulfilling
your obligation to employ commercially reasonable efforts to
assist
Spectrum in pre-clinical development, the obligation raises the
question of whether, in the absence of your continuing
involvement,
Spectrum would have paid the amounts you have recognized as
upfront
revenues. It is unclear why this obligation, combined with the
requirement that you attend regular meetings of the Joint
Development
Committee, is not analogous to that described in the second bullet
point in the Facts of question one in SAB Topic 13:A3(f). Please
advise.
* * * *
Please respond to these comments within 10 business days
or
tell us when you will provide us with a response. Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information. Detailed letters greatly
facilitate our review.
You may contact Scott Watkinson, Staff Accountant, at (202)
551-3741, or in his absence, me at (202) 551-3769 with any other
questions.
Sincerely,
Rufus Decker
Accounting Branch Chief
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Alan J. Gotcher
Altair Nanotechnologies, Inc.
August 19, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
</TEXT>
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