SEC Comment Letter for IGATE CORP (CIK 0001024732) — Jun 6, 2005
IGATE CORP (CIK 0001024732)
Date: June 6, 2005 · CIK: 0001024732 · Accession: 0000000000-05-028081
AI Filing Summary & Sentiment
File numbers found in text: 000-21755
Letter
Room 4561 June 6, 2005 Mr. Michael J. Zugay Senior Vice President, Chief Financial Officer and Corporate Secretary 1000 Commerce Drive Suite 500 Pittsburgh, PA 15275
Re: iGATE Corporation Item 4.01 Form 8-K Filed May 25, 2005 File No. 000-21755
Dear Mr. Zugay:
We have reviewed your filing and have the following comments. We may ask you to provide us with more information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. After reviewing this information, we may or may not 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
1. Describe in more detail the nature of each of the three material weaknesses you identified. Tell us in what period the material weaknesses occurred and when they were identified. Tell us in detail the steps you have taken (or plan to take) and procedures you implemented (or plan to implement) to correct each material weakness.
2. Please provide us with a schedule of your fiscal year end fourth quarter adjustments to close the books, or adjustments recorded in connection with or as a result of the audit. Clearly explain the reason for each adjustment. For each adjustment, show us the impact on pre- tax net loss. Quantify the net effect of all adjustments on pre-tax net income (loss). Also, tell us why none of the adjustments relate to prior periods. Explain in detail why you believe the timing of each adjustment is appropriate.
3. Provide us with any letter or written communication to and from the former accountants regarding any disagreements or reportable events to management or the Audit Committee.
As appropriate, please respond to these comments within five business days or tell us when you will respond. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. Please furnish a cover letter that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the disclosure in the filing;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
You may contact Christine Davis, Staff Accountant, at (202) 551- 3408, Robert Benton, Review Accountant at (202) 551-3804 or me at (202) 551-3226 if you have questions regarding these comments.
Sincerely,
Craig Wilson
Senior Assistant Chief
Accountant
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Show Raw Text
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<TEXT>
Room 4561
June 6, 2005
Mr. Michael J. Zugay
Senior Vice President, Chief Financial Officer
and Corporate Secretary
1000 Commerce Drive
Suite 500
Pittsburgh, PA 15275
Re: iGATE Corporation
Item 4.01 Form 8-K
Filed May 25, 2005
File No. 000-21755
Dear Mr. Zugay:
We have reviewed your filing and have the following
comments.
We may ask you to provide us with more information so we may
better
understand your disclosure. Please be as detailed as necessary in
your explanation. After reviewing this information, we may or may
not 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
1. Describe in more detail the nature of each of the three
material
weaknesses you
identified. Tell us in what period the material weaknesses
occurred
and when they were identified. Tell us in detail the steps you
have
taken (or plan to take) and procedures you implemented (or plan to
implement) to correct each material weakness.
2. Please provide us with a schedule of your fiscal year end
fourth
quarter
adjustments to close the books, or adjustments recorded in
connection
with or as a result of the audit. Clearly explain the reason for
each adjustment. For each adjustment, show us the impact on pre-
tax
net loss. Quantify the net effect of all adjustments on pre-tax
net
income (loss). Also, tell us why none of the adjustments relate
to
prior periods. Explain in detail why you believe the timing of
each
adjustment is appropriate.
3. Provide us with any letter or written communication to and from
the former
accountants regarding any disagreements or reportable events to
management or the Audit Committee.
As appropriate, please respond to these comments within
five
business days or tell us when you will respond. Please submit all
correspondence and supplemental materials on EDGAR as required by
Rule 101 of Regulation S-T. Please furnish a cover letter that
keys
your responses to our comments and provides any requested
information. Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Christine Davis, Staff Accountant, at (202)
551-
3408, Robert Benton, Review Accountant at (202) 551-3804 or me at
(202) 551-3226 if you have questions regarding these comments.
Sincerely,
Craig Wilson
Senior Assistant Chief
Accountant
??
??
??
??
Michael J. Zugay
iGATE Corporation
June 6, 2005
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