SEC Comment Letter for AMDOCS LTD (DOX) (CIK 0001062579) (DOX) — Mar 25, 2009
AMDOCS LTD (DOX) (CIK 0001062579)
Date: March 25, 2009 · CIK: 0001062579 · Accession: 0000000000-09-015136
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-14840
Referenced dates: February 23, 2009, February 6, 2009
Letter
Mail Stop 4561 March 24, 2009 Dov Baharav Chief Executive Officer Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, Missouri 63017 Re: Amdocs Limited Form 20-F for the Fiscal Year Ended September 30, 2008 Filed December 8, 2008 File No. 001-14840
Dear Mr. Baharav:
We have reviewed your response letter dated February 23, 2009 in connection with the above-referenced filing and have the following comment. If indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this inform ation, we may raise additional comments. Unless otherwise noted, where prior comments ar e referred to they refer to our letter dated February 6, 2009. Form 20-F for the Fiscal Year Ended September 30, 2008
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Note 3 – Acquisitions, page F-18 1. We note your response to prior comment number 2. Please explain why establishing the valuation a llowance had no effect on your income statement. As part of your response, address the fact that this adjustment was the correction of a purchase price allocation error.
* * * * * * *
Dov Baharav Amdocs Limited March 24, 2009 Page 2 Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your filing(s), you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter that keys your response to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comm ents after reviewing any amendment and your response to our comment. You may contact David Edga r, Staff Accountant, at (202) 551-3459, Christine Davis, Assistant Chief Accountant, at ( 202) 551-3408, or me at (202) 551-3451 if you have questions regarding the above comment. S i n c e r e l y , Mark Kronforst Accounting Branch Chief
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Mail Stop 4561 March 24, 2009 Dov Baharav Chief Executive Officer Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, Missouri 63017
Re: Amdocs Limited
Form 20-F for the Fiscal Year Ended September 30, 2008
Filed December 8, 2008
File No. 001-14840
Dear Mr. Baharav:
We have reviewed your response letter dated February 23, 2009 in connection
with the above-referenced filing and have the following comment. If indicated, we think
you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detaile d as necessary in your explan ation. In our comment, we
may ask you to provide us with supplemental information so we may better understand
your disclosure. After reviewing this inform ation, we may raise additional comments.
Unless otherwise noted, where prior comments ar e referred to they refer to our letter
dated February 6, 2009. Form 20-F for the Fiscal Year Ended September 30, 2008
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Note 3 – Acquisitions, page F-18
1. We note your response to prior comment number 2. Please explain why
establishing the valuation a llowance had no effect on your income statement. As
part of your response, address the fact that this adjustment was the correction of a
purchase price allocation error.
* * * * * * *
Dov Baharav
Amdocs Limited March 24, 2009 Page 2
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please submit all correspondence and supplemental materials
on EDGAR as required by Rule 101 of Regulation S-T. If you amend your filing(s), you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter that keys your response to our comment and provides any
requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comm ents after reviewing any amendment and
your response to our comment.
You may contact David Edga r, Staff Accountant, at (202) 551-3459, Christine
Davis, Assistant Chief Accountant, at ( 202) 551-3408, or me at (202) 551-3451 if you
have questions regarding the above comment.
S i n c e r e l y , Mark Kronforst
Accounting Branch Chief