SEC Comment Letter for AMDOCS LTD (DOX) (CIK 0001062579) (DOX) — Mar 11, 2014
AMDOCS LTD (DOX) (CIK 0001062579)
Date: March 11, 2014 · CIK: 0001062579 · Accession: 0000000000-14-012168
AI Filing Summary & Sentiment
Reasoning
Letter
March 11, 2014 Via E -mail Tamar Rapaport -Dagim Chief Financial Officer Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, MO 63017
Re: Amdocs Limited Form 20-F for the Fiscal Year Ended September 30, 2013 Filed December 9, 2013 File No. 00 1-14840
Dear Ms. Rapaport -Dagim :
We have reviewed your filing an d have the following comments . In some of our comments , 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 advising us when you will provide th e requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you prov ide in response to these comment s, we may have additional comments.
Form 20 -F for the Fiscal Year Ended September 30, 2013
Consolidated Financial Statements
Note 16 – Contingencies
Legal Proceedings, page F -29
1. We note recent news articles regarding pending proceedings and arbitration with T-Jat Systems (2006) Ltd . Please provide us with a summarized timeline of the significant events pertaining to this matter. Tell us how you evaluated any related contingent l oss disclosures related to this matter considering the guidance in ASC 450 -20-50.
2. You disclose that the Company believes that the results of any such contingencies, either individually or in the aggregate, will not have a material adverse effect on the C ompany’s
Tamar Rapaport -Dagim Amdocs Limited March 11, 2014 Page 2
financial position, results of operations or cash flows. Please t ell us what consideration was given to disclosing an estimate of reasonably possible losses in excess of amounts accrued, if material, or that such an estimate of the possible loss or range of loss cannot be made. Refer to paragraphs 3 through 5 of ASC 450 -20-50.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. 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 ma de.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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 o f the United States.
You may contact Joyce Sweeney, Staff Accountant , at (202) 551 -3449 if you have questions regarding these comments. If you require further assistance, do not hesitate to contact me at (202) 551 -3406 .
Sincerely,
/s/ Patrick Gilmore
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March 11, 2014 Via E -mail Tamar Rapaport -Dagim Chief Financial Officer Amdocs Limited 1390 Timberlake Manor Parkway Chesterfield, MO 63017 Re: Amdocs Limited Form 20-F for the Fiscal Year Ended September 30, 2013 Filed December 9, 2013 File No. 00 1-14840 Dear Ms. Rapaport -Dagim : We have reviewed your filing an d have the following comments . In some of our comments , 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 advising us when you will provide th e requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you prov ide in response to these comment s, we may have additional comments. Form 20 -F for the Fiscal Year Ended September 30, 2013 Consolidated Financial Statements Note 16 – Contingencies Legal Proceedings, page F -29 1. We note recent news articles regarding pending proceedings and arbitration with T-Jat Systems (2006) Ltd . Please provide us with a summarized timeline of the significant events pertaining to this matter. Tell us how you evaluated any related contingent l oss disclosures related to this matter considering the guidance in ASC 450 -20-50. 2. You disclose that the Company believes that the results of any such contingencies, either individually or in the aggregate, will not have a material adverse effect on the C ompany’s Tamar Rapaport -Dagim Amdocs Limited March 11, 2014 Page 2 financial position, results of operations or cash flows. Please t ell us what consideration was given to disclosing an estimate of reasonably possible losses in excess of amounts accrued, if material, or that such an estimate of the possible loss or range of loss cannot be made. Refer to paragraphs 3 through 5 of ASC 450 -20-50. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. 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 ma de. In responding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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 o f the United States. You may contact Joyce Sweeney, Staff Accountant , at (202) 551 -3449 if you have questions regarding these comments. If you require further assistance, do not hesitate to contact me at (202) 551 -3406 . Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief