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SEC Company Response from INDUS INTERNATIONAL INC (CIK 0001041333) — Jun 1, 2005

INDUS INTERNATIONAL INC (CIK 0001041333)
Date: June 1, 2005 · CIK: 0001041333 · Accession: 0000950144-05-006098

AI Filing Summary & Sentiment

Date
June 1, 2005
Author
/s/ Thomas W. Williams
Form
CORRESP
Company
INDUS INTERNATIONAL INC (CIK 0001041333)

Letter

Ms. Kari Jin Securities and Exchange Commission 100 F. Street N.E. Washington, D.C. 20549

Dear Ms. Jin:

In response to your letter

to Thomas W. Williams, Chief Financial Officer of Indus International, Inc. dated May 24, 2005, Indus has filed today an amended Current Report on

Form 8-K that discloses that it will restate its previously issued financial statements in its Annual

Report on Form 10-K for Fiscal 2005 that is scheduled to be filed in the next two weeks. The Annual Report will include restated financial information for each of the annual and transition periods discussed, as well as condensed restated financial information for each of the quarters in Fiscal 2005 and Fiscal 2004. Further, the Company’s Quarterly Reports on Form 10-Q for Fiscal 2006

will reflect the complete, restated financial information for the corresponding quarters in Fiscal

2005. As a result of its previous disclosure of the restated financial information for Fiscal 2004 and Fiscal 2005 in the Current Report on Form 8-K filed by Indus on May 10, 2005, Indus’s intent to include the restated financial information discussed above in its Annual Report and the imminent filing of such Report, Indus

has determined that it is not necessary to file amendments to additional Exchange Act reports to reflect the same restated financial information that will be included in the Annual Report.

As requested in your

letter, Indus hereby acknowledges the following:

• Indus is responsible for the adequacy and accuracy of the disclosure in the amended Form 8-K;

• Staff comments or changes in disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

• Indus 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.

Please feel free to call

either myself (770) 989-4300 or our General Counsel, Adam V. Battani, at (770) 989-4061.

Regards,
/s/ Thomas W. Williams

Show Raw Text
CORRESP
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SEC RESPONSE LETTER

[Indus Letterhead]

June 1, 2005

Ms. Kari Jin

Securities and Exchange Commission

100 F. Street N.E.

Washington, D.C. 20549

Dear Ms. Jin:

     In response to your letter

to Thomas W. Williams, Chief Financial Officer of Indus
International, Inc. dated May 24, 2005, Indus has filed today an amended Current Report on

Form 8-K
that discloses that it will restate its previously issued financial statements in its Annual

Report
on Form 10-K for Fiscal 2005 that is scheduled to be filed in the next two weeks. The Annual
Report will include restated financial information for each of the annual and transition periods
discussed, as well as condensed restated financial information for each of the quarters in Fiscal
2005 and Fiscal 2004. Further, the Company’s Quarterly Reports on Form 10-Q for Fiscal 2006

will
reflect the complete, restated financial information for the corresponding quarters in Fiscal

2005.
As a result of its previous disclosure of the restated financial information for Fiscal 2004
and Fiscal 2005 in the Current Report on Form 8-K filed by Indus on May 10, 2005, Indus’s
intent to include the restated financial information discussed above in its Annual Report and the imminent filing of such Report, Indus

has
determined that it is not necessary to file amendments to additional Exchange Act reports to
reflect the same restated financial information that will be included in the Annual Report.

     As requested in your

letter, Indus hereby acknowledges the following:

    •
    Indus is responsible for the adequacy and accuracy of the disclosure in the amended
Form 8-K;

    •
    Staff comments or changes in disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

    •
    Indus 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.

     Please feel free to call

either myself (770) 989-4300 or our General Counsel, Adam V.
Battani, at (770) 989-4061.

Regards,

/s/ Thomas W. Williams

Thomas W. Williams

Executive Vice President and

Chief Financial Officer

    cc:

    Gregory J. Dukat, President and Chief Executive Officer

    Adam V. Battani, General Counsel

    William S. Ortwein, Alston & Bird LLP