SEC Comment Letter for AMDOCS LTD (DOX) (CIK 0001062579) (DOX) — Mar 8, 2011
AMDOCS LTD (DOX) (CIK 0001062579)
Date: March 8, 2011 · CIK: 0001062579 · Accession: 0000000000-11-014631
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-14840
Referenced dates: January 26, 2011
Letter
March 8, 2011 Via Facsimile Mr. Thomas G. O’Brien Treasurer and Secretary Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, Missouri 63017 Re: Amdocs Limited Form 20-F for the Fiscal Year Ended September 30, 2010 Filed December 7, 2010 File No. 001-14840
Dear Mr. O’Brien: We have reviewed your letter dated Februa ry 9, 2011 in connection with the above- referenced filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comment applies to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment, we may have addi tional comments. Unless otherwise noted, where prior comments are referred to they refe r to our letter dated January 26, 2011
General
1. We note that your response includes the repres entations requested at the end of our prior comment letter but that your response was signed by Mr. Robert Sc hwed, your outside counsel, and was issued on the outside couns el letterhead. Please confirm that Mr. Schwed is authorized to act as your agent.
Mr. Thomas G. O’Brien Amdocs Limited March 8, 2011 Page 2 Form 20-F for the Fiscal Year Ended September 30, 2010
Item 8. Financial Information Note 2 – Summary of Significant Accounting Policies
Revenue Recognition, page F-11
2. We note that your response to prior commen t 2 indicates that you determine VSOE of fair value when a “substantial majority of sta ndalone deals in the study fall within a range of plus or minus 15% from th e midpoint.” Please tell us what percentage you believe represents a “substantial majority” and w hy you believe that percentage constitutes a range that is sufficiently cluste red to support a conclusion that VSOE of fair value exists. Additionally, describe how you determine VSOE of fair value for arrangements that are outside of the range. You may contact Jaime John at (202) 551-3446 if you have questions regarding comments on the financial statements and relate d matters. Please contact me at (202) 551-3406 with any other questions. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief
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March 8, 2011 Via Facsimile Mr. Thomas G. O’Brien Treasurer and Secretary Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, Missouri 63017 Re: Amdocs Limited Form 20-F for the Fiscal Year Ended September 30, 2010 Filed December 7, 2010 File No. 001-14840 Dear Mr. O’Brien: We have reviewed your letter dated Februa ry 9, 2011 in connection with the above- referenced filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comment applies to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have addi tional comments. Unless otherwise noted, where prior comments are referred to they refe r to our letter dated January 26, 2011 General 1. We note that your response includes the repres entations requested at the end of our prior comment letter but that your response was signed by Mr. Robert Sc hwed, your outside counsel, and was issued on the outside couns el letterhead. Please confirm that Mr. Schwed is authorized to act as your agent. Mr. Thomas G. O’Brien Amdocs Limited March 8, 2011 Page 2 Form 20-F for the Fiscal Year Ended September 30, 2010 Item 8. Financial Information Note 2 – Summary of Significant Accounting Policies Revenue Recognition, page F-11 2. We note that your response to prior commen t 2 indicates that you determine VSOE of fair value when a “substantial majority of sta ndalone deals in the study fall within a range of plus or minus 15% from th e midpoint.” Please tell us what percentage you believe represents a “substantial majority” and w hy you believe that percentage constitutes a range that is sufficiently cluste red to support a conclusion that VSOE of fair value exists. Additionally, describe how you determine VSOE of fair value for arrangements that are outside of the range. You may contact Jaime John at (202) 551-3446 if you have questions regarding comments on the financial statements and relate d matters. Please contact me at (202) 551-3406 with any other questions. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief