SEC Comment Letter for EUROTRUST A — Sep 23, 2005
EUROTRUST A/S (CIK 0001041457)
Date: Sept. 23, 2005 · CIK: 0001041457 · Accession: 0000000000-05-049420
AI Filing Summary & Sentiment
Referenced dates: August 3, 2005, September 21, 2005
Letter
Mail Stop 3561 September 23, 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 File No. 0-30690
Dear Mr. Degn:
We have reviewed your supplemental response letter dated September 21, 2005 as well as your filing and have the following comment. As noted in our comment letter dated August 3, 2005, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
Form 20-F for Fiscal Year Ended December 31, 2004
Note 7: Business Acquisitions and Divestitures; page F-23
1. We note your response to previous comment 1. We note that you did not classify EuroTrust Realtime Security A/S, EuroTrust PKI and Virus 112 A/S as discontinued operations because of the royalty payments received by EuroTrust Secure Hosting A/S and EuroTrust NetVaulting A/S. However, it is unclear to us why, as requested by paragraph of SFAS 144, you did not consider EuroTrust Realtime Security A/S, EuroTrust PKI and Virus 112 A/S to be components. Revise or advise in detail.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. 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 if you have any other questions.
Sincerely,
Larry Spirgel
Assistant Director
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 3561
September 23, 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
File No. 0-30690
Dear Mr. Degn:
We have reviewed your supplemental response letter dated
September 21, 2005 as well as your filing and have the following
comment. As noted in our comment letter dated August 3, 2005, we
have limited our review to your financial statements and related
disclosures and do not intend to expand our review to other
portions
of your documents.
Form 20-F for Fiscal Year Ended December 31, 2004
Note 7: Business Acquisitions and Divestitures; page F-23
1. We note your response to previous comment 1. We note that you
did
not classify EuroTrust Realtime Security A/S, EuroTrust PKI and
Virus
112 A/S as discontinued operations because of the royalty payments
received by EuroTrust Secure Hosting A/S and EuroTrust NetVaulting
A/S. However, it is unclear to us why, as requested by paragraph
41
of SFAS 144, you did not consider EuroTrust Realtime Security A/S,
EuroTrust PKI and Virus 112 A/S to be components. Revise or
advise
in detail.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. 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 if you have any
other
questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Soren Degn
EuroTrust A/S
September 23, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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