SEC Comment Letter for EUROTRUST A — Aug 3, 2005
EUROTRUST A/S (CIK 0001041457)
Date: Aug. 3, 2005 · CIK: 0001041457 · Accession: 0000000000-05-039996
AI Filing Summary & Sentiment
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Mail Stop 3561
August 3, 2005
Via Mail and Fax (3954-0001)
Mr. Soren Degn
Chief Financial Officer
EuroTrust A/S
Poppelgaardvej 11-13
2860 Soeborg
Denmark
Re: EuroTrust A/S
Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 3, 2005
Dear Mr. Degn:
We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents. Please address the following comments
in
future filings. If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a future 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 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 on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 20-F for Fiscal Year Ended December 31, 2004
Consolidated Statements of Operations; page F-5
1. In future periods, please revise your presentation to comply
with
SAB Topic 11:B.
Note 7: Business Acquisitions and Divestitures; page F-23
2. Tell us in detail how you concluded that the divestitures of
all
of your related internet businesses disposed in 2003 and 2004
should
not be classified as discontinued operations. In your response
address EITF 03-13 and paragraph 42 of SFAS 144.
3. In your disclosure regarding the acquisition of Ideation House
ApS, and the subsequent divestiture of InAphone A/S, it is unclear
to
us whether you have recorded a gain or loss on the divestiture.
Explain to us your accounting for the sale of this subsidiary.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
letter that keys your responses to our comments and provides any
requested information. Detail letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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 filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.
You may contact Dave Walz, Staff Accountant, at (202) 551-
3358
or Carlos Pacho, Senior Assistant Chief Accountant, at (202) 551-
3835
if you have questions regarding comments on the financial
statements
and related matters. Please contact me at (202) 551-3810 with any
other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Soren Degn
EuroTrust A/S
August 3, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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