SEC Comment Letter for AEHR TEST SYSTEMS (AEHR) (CIK 0001040470) (AEHR) — Oct 2, 2007
AEHR TEST SYSTEMS (AEHR) (CIK 0001040470)
Date: Oct. 2, 2007 · CIK: 0001040470 · Accession: 0000000000-07-047925
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-22893
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549
DIVISION OF CORPORATION FINANCE
Mail Stop 6010 September 26, 2007
VIA U.S. MAIL and FACSIMILE
Mr. Gary L. Larson Chief Financial Officer Aehr Test Systems 400 Kato Terrace Fremont, CA 94539 RE: Aehr Test Systems Form 10-K for the fiscal year ended May 31, 2007 Filed August 29, 2007 File No. 000-22893 Dear Mr. Larson: We have reviewed your filing and have the following comments. Where indicated, we think you should re vise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments. Please understand that the purpose of our re view 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.
Mr. Gary L. Larson Aehr Test Systems September 26, 2007 Page 2 Form 10-K for the fiscal year ended May 31, 2007
Notes to Consolidated Financial Statements
Note 1. Organization and Summary of Significant Accounting Policies
Revenue Recognition, page 38 1. We see that you recognize royalty revenue re lated to licensing income when paid by the licensee. Under SAB 104, revenue is considered earned and realized or realizable once persuasive evidence of an arrangement exists, services have been rendered, the seller’s price to the buyer is fixed or determinable and collectibility is reasonably assured. Please tell us and disclose in future filings why income from licensing arrangement is not earned and realizable until the amounts are paid by the licensee. Refer to the acc ounting literature upon which you relied. As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your response that keys your responses to our comments and provides any requested information. Detailed cover le tters greatly facilitate our re view. Please understand that we may have additional comments after re viewing your responses to our comments. We urge all persons who are responsi ble for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed 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 comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
Mr. Gary L. Larson Aehr Test Systems September 26, 2007 Page 3 In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing. You may contact Jong Hwang at (202) 551- 3327 or Kristin Lochhead at (202) 551-3664 if you have questions. In this regar d, please do not hesitate to contact me at (202) 551-3676 with any other questions. Sincerely,
Brian Cascio Accounting Branch Chief
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 6010
September 26, 2007
VIA U.S. MAIL and FACSIMILE
Mr. Gary L. Larson Chief Financial Officer
Aehr Test Systems
400 Kato Terrace Fremont, CA 94539
RE: Aehr Test Systems
Form 10-K for the fiscal year ended May 31, 2007
Filed August 29, 2007
File No. 000-22893
Dear Mr. Larson:
We have reviewed your filing and have the following comments. Where
indicated, we think you should re vise your document in response to these comments. If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary. Please be as deta iled as necessary in your explanation. In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure. After reviewing th is information, we may raise additional
comments. Please understand that the purpose of our re view 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.
Mr. Gary L. Larson
Aehr Test Systems
September 26, 2007
Page 2 Form 10-K for the fiscal year ended May 31, 2007
Notes to Consolidated Financial Statements
Note 1. Organization and Summary of Significant Accounting Policies
Revenue Recognition, page 38
1. We see that you recognize royalty revenue re lated to licensing income when paid
by the licensee. Under SAB 104, revenue is considered earned and realized or
realizable once persuasive evidence of an arrangement exists, services have been
rendered, the seller’s price to the buyer is fixed or determinable and collectibility
is reasonably assured. Please tell us and disclose in future filings why income
from licensing arrangement is not earned and realizable until the amounts are paid
by the licensee. Refer to the acc ounting literature upon which you relied.
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Please furnish a cover letter with your
response that keys your responses to our comments and provides any requested
information. Detailed cover le tters greatly facilitate our re view. Please understand that
we may have additional comments after re viewing your responses to our comments.
We urge all persons who are responsi ble for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
Mr. Gary L. Larson
Aehr Test Systems September 26, 2007
Page 3
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing. You may contact Jong Hwang at (202) 551- 3327 or Kristin Lochhead at (202)
551-3664 if you have questions. In this regar d, please do not hesitate to contact me at
(202) 551-3676 with any other questions.
Sincerely,
Brian Cascio Accounting Branch Chief