SEC Comment Letter for AMDOCS LTD (DOX) (CIK 0001062579) (DOX) — Oct 11, 2006
AMDOCS LTD (DOX) (CIK 0001062579)
Date: Oct. 11, 2006 · CIK: 0001062579 · Accession: 0000000000-06-049122
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-14840
Referenced dates: April 20, 2006
Letter
Room 4561 July 18, 2006 Mr. Thomas G. O’Brien Treasurer and Secretary Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, MO 63017
Re: Amdocs Limited Form 20-F for Fiscal Year Ended September 30, 2005 Filed December 28, 2005 Form 6-K filed April 27, 2006 Form 6-K filed May 17, 2006 File No. 001-14840
Dear Mr. O’Brien:
We have reviewed your response to our letter dated April 20, 2006 in connection with our review of the above referenced filings and have the following comments. Please note that we have limited our review to the ma tters addressed in the comments below. We may ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as n ecessary in your explanation. After reviewing this 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.
Form 6-K filed April 27, 2006 1. We have reviewed your response to prior comment number 9 from our letter dated April 20, 2006 concerning the non- GAAP operating statement columnar format. We continue to have the co ncerns previously expressed over how investors might view that information due to the format in which it has been presented. As noted in our prior comme nt, we believe the non-GAAP operating statement columnar format may create th e unwarranted impression to investors
Mr. Thomas G. O’Brien Amdocs Limited June 26, 2006 Page 2 that the non-GAAP operating statement has been prepared under a comprehensive set of accounting rules or principles while also conveying undue prominence to a statement based on non-GAAP measures. C onsequently, we believe is should be removed. As a substitute for this presentation format, you may consider presenting only individual non-GAAP measures (i.e., line items, subtotals, etc.) provided each one complies with Item 10 of Reg. S-K and the Division of Corporation Finance’s Frequently Aske d Questions Regarding Use of Non-GAAP Financial Measures, Question 8.
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provid e us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. You may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cove r letter with any amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing any amendment and your responses to our comments.
You may contact Marc Thom as, Senior Staff Accountan t at (202) 551-3452 or me at (202) 551-3730 if you have questions rega rding comments on the financial statements and related matters.
Sincerely,
Brad Skinner
Accounting Branch Chief
Show Raw Text
Room 4561
July 18, 2006
Mr. Thomas G. O’Brien
Treasurer and Secretary
Amdocs Limited
1390 Timberlake Manor Parkway
Chesterfield, MO 63017
Re: Amdocs Limited
Form 20-F for Fiscal Year Ended September 30, 2005
Filed December 28, 2005
Form 6-K filed April 27, 2006
Form 6-K filed May 17, 2006
File No. 001-14840
Dear Mr. O’Brien:
We have reviewed your response to our letter dated April 20, 2006 in connection
with our review of the above referenced filings and have the following comments. Please
note that we have limited our review to the ma tters addressed in the comments below. We
may ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as n ecessary in your explanation. After reviewing
this 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.
Form 6-K filed April 27, 2006
1. We have reviewed your response to prior comment number 9 from our letter dated April 20, 2006 concerning the non- GAAP operating statement columnar
format. We continue to have the co ncerns previously expressed over how
investors might view that information due to the format in which it has been
presented. As noted in our prior comme nt, we believe the non-GAAP operating
statement columnar format may create th e unwarranted impression to investors
Mr. Thomas G. O’Brien
Amdocs Limited
June 26, 2006 Page 2
that the non-GAAP operating statement has been prepared under a comprehensive
set of accounting rules or principles while also conveying undue prominence to a
statement based on non-GAAP measures. C onsequently, we believe is should be
removed. As a substitute for this presentation format, you may consider
presenting only individual non-GAAP measures (i.e., line items, subtotals, etc.)
provided each one complies with Item 10 of Reg. S-K and the Division of
Corporation Finance’s Frequently Aske d Questions Regarding Use of Non-GAAP
Financial Measures, Question 8.
As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response. Please submit all
correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. You may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cove r letter with any amendment that keys your
responses to our comments and provides any requested information. Detailed cover
letters greatly facilitate our review. Please understand that we may have additional comments after reviewing any amendment and your responses to our comments.
You may contact Marc Thom as, Senior Staff Accountan t at (202) 551-3452 or me
at (202) 551-3730 if you have questions rega rding comments on the financial statements
and related matters.
Sincerely,
Brad Skinner
Accounting Branch Chief