SEC Comment Letter for INDUS INTERNATIONAL INC (CIK 0001041333) — May 24, 2005
INDUS INTERNATIONAL INC (CIK 0001041333)
Date: May 24, 2005 · CIK: 0001041333 · Accession: 0000000000-05-025680
AI Filing Summary & Sentiment
File numbers found in text: 000-22993
Letter
May 24, 2005 Mail Room 4561 Thomas Williams EVP & CFO Indus International, Inc. 3301 Windy Ridge Parkway Atlanta, GA 30339
Re: Item 4.02 Form 8-K Filed on 5/10/05 File No. 000-22993
Dear Mr. Williams,
We have reviewed your Item 4.02 Form 8-K for compliance with the form requirement and have the following comments.
We note that you plan to restate the Company`s financial statements for fiscal year 2000, 2001, 2002, 2003, 2004 and 2005. Please amend to clarify which Exchange Act reports will be amended and disclose your anticipated timing for filing of the amendments.
You should file your amendment as a Form 8-K/A in response to this comment within five business days from the date of letter.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that 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 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.
If you have any questions, please call Kari Jin, Staff Accountant at (202) 551-3481.
Sincerely,
Kari Jin
Staff Accountant
Show Raw Text
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<TEXT>
May 24, 2005
Mail Room 4561
Thomas Williams
EVP & CFO
Indus International, Inc.
3301 Windy Ridge Parkway
Atlanta, GA 30339
Re: Item 4.02 Form 8-K
Filed on 5/10/05
File No. 000-22993
Dear Mr. Williams,
We have reviewed your Item 4.02 Form 8-K for compliance with
the
form requirement and have the following comments.
We note that you plan to restate the Company`s financial
statements for fiscal year 2000, 2001, 2002, 2003, 2004 and 2005.
Please amend to clarify which Exchange Act reports will be amended
and disclose your anticipated timing for filing of the amendments.
You should file your amendment as a Form 8-K/A in response to
this comment within five business days from the date of letter.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that 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 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.
If you have any questions, please call Kari Jin, Staff
Accountant
at (202) 551-3481.
Sincerely,
Kari Jin
Staff Accountant
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Mr. Williams
Indus International, Inc.
May 24, 2005
Page 2
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