SEC Company Response from AMDOCS LTD (DOX) (CIK 0001062579) (DOX) — May 31, 2005
AMDOCS LTD (DOX) (CIK 0001062579)
Date: May 31, 2005 · CIK: 0001062579 · Accession: 0000950123-05-006934
AI Filing Summary & Sentiment
File numbers found in text: 333-114344
Referenced dates: May 23, 2005
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AMDOCS
May 31, 2005
VIA EDGAR
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SECURITIES AND EXCHANGE COMMISSION
Division of Corporation Finance
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC 20549
Attention: Jeffrey Werbitt
Re: AMDOCS LIMITED
Post-Effective Amendment No. 6 to Form F-3
filed on May 31, 2005 (File No. 333-114344)
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Ladies and Gentlemen:
On behalf of Amdocs Limited (the "Company"), please find below an
acknowledgment of the Company as requested by the staff (the "Staff") of the
Securities and Exchange Commission (the "Commission") in the letter dated May
23, 2005, from Mr. Mark Shuman, Branch Legal Chief, Division of Corporation
Finance of the Commission. The comment letter relates to the above-referenced
Post-Effective Amendment (the "Amendment") to Registration Statement on Form F-3
(the "Form F-3") filed by the Company with the Commission on May 31, 2005.
In the comment letter, the Staff requested that the Company acknowledge
certain matters with respect to the Amendment filing. Specifically, the Staff
provided the following comment:
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to be
certain that they have provided all information investors require for an
informed decision. 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 made.
Please furnish a letter acknowledging that:
o should the Commission or the staff, acting pursuant to
delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect
to the filing;
o the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does
not relieve the company from its full responsibility for the
adequacy and accuracy of the disclosure in the filing; and
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o the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the Division of
Corporation Finance in connection with our review of your filing or in
response to our comments on your filing.
By this letter, the Company hereby acknowledges that, should the
Commission or the Staff, acting pursuant to delegated authority, declare the
Amendment effective, it does not foreclose the Commission from taking any action
with respect to the Amendment. The Company further acknowledges to the
Commission that the action of the Commission or the Staff, acting pursuant to
delegated authority, in declaring the Amendment effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the
disclosure in the Amendment. The Company acknowledges that it may not assert
this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States, and that the
Division of Enforcement has access to all information provided to the Staff of
the Division of Corporation Finance in connection with the review of the
Amendment or in response to Staff comments on the Amendment.
[THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK]
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Please do not hesitate to contact the undersigned at 314-212-8383 with
any questions regarding this response letter or the above acknowledgement.
Very truly yours,
/s/ Thomas G. O'Brien
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Thomas G. O'Brien
Secretary and Treasurer
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