SEC Comment Letter for ASI ENTERTAINMENT INC (CIK 0001067873) — May 9, 2005
ASI ENTERTAINMENT INC (CIK 0001067873)
Date: May 9, 2005 · CIK: 0001067873 · Accession: 0000000000-05-022450
AI Filing Summary & Sentiment
Letter
May 11, 2005 Via US Mail and Facsimile Philip A. Shiels Chief Financial Officer ASI Entertainment, Inc. 1/12, Candlebark Court Research, Victoria 3095 Australia
Re: ASI Entertainment Form 10-KSB for the year ended June 30, 2004 Commission File Number: 0-27881
Dear Mr. Shiels,
We have reviewed your May 3, 2005 response letter and have the following comments. Where expanded or revised disc losure is requested, you may co mply with these comments in future filings. If you disagree, we will consid er your explanation as to why our comments are inapplicable or a revision is unnecessary. We also ask you to provide us with supplemental information so we may better understand your disclosu re. Please be as deta iled as necessary in your explanation. We look forward to working with you in these resp ects and welcome any questions you may have about any aspects of our review.
* * * * * * * * * * * 1. Refer to our prior comment 3. We understan d, from your response, that the technological feasibility of the G3CARS wa s not established until Februa ry 2005. If our understanding is correct, then it appears that al l related costs incurred prior to that time were properly expensed. From the date that technological f easibility was establishe d in February 2005, we would expect production costs to be capitalized if appropriate under paragraph 5 of SFAS 86. We would also expect capitalization of comput er software costs to cease when the product was available for general release to customer s. Maintenance and customer support costs should be charged to expense in the manner speci fied by paragraph 6 of the above referenced statement.
2. It appears, from your response, you intend to capita lize certain costs you incurred in fiscal 2003 and 2004 for G3CARS. If these costs were incurred prior to February 2005, it appears to us that the costs were properly expens ed when incurred. After establishment of technological feasibility, it w ould not be appropriate to rest ate prior fiscal periods to
ASI Enterta iment, Inc. March 3, 2004 Page 2
subsequently capitalize costs that were previo usly considered to be R&D costs. Please supplementally explain when and why the fi scal 2004 costs ($77,074) and the fiscal 2003 costs ($42,095) were incurred, how they were accounted for and why it is now appropriate to capitalize them. * * * * * * * * * * *
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amen dment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional co mments after reviewing your am endment and responses to our comments.
We urge all persons who are responsible fo r the accuracy and adequa cy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision. Since the comp any and its management are in possession of all facts relating to a company’s disclosure, they ar e responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of the United States.
In addition, please be advi sed that the Division of Enforcement has access to all information you provide to the staff of the Divisi on of Corporation Finance in our review of your filing or in response to our comments on your filing.
You may contact Amy McGann at 202- 551-3304 or Marger y Reich at 202-551- 3347 if you have questions regarding comments on the financial stat ements and related matters. Please contact me at 202-551-3211 with any other questions.
S i n c e r e l y ,
David R. Humphrey B r a n c h C h i e f
Show Raw Text
May 11, 2005
Via US Mail and Facsimile
Philip A. Shiels
Chief Financial Officer
ASI Entertainment, Inc.
1/12, Candlebark Court
Research, Victoria 3095 Australia
Re: ASI Entertainment
Form 10-KSB for the year ended June 30, 2004
Commission File Number: 0-27881
Dear Mr. Shiels,
We have reviewed your May 3, 2005 response letter and have the following comments.
Where expanded or revised disc losure is requested, you may co mply with these comments in
future filings. If you disagree, we will consid er your explanation as to why our comments are
inapplicable or a revision is unnecessary. We also ask you to provide us with supplemental
information so we may better understand your disclosu re. Please be as deta iled as necessary in
your explanation. We look forward to working with you in these resp ects and welcome any
questions you may have about any aspects of our review.
* * * * * * * * * * *
1. Refer to our prior comment 3. We understan d, from your response, that the technological
feasibility of the G3CARS wa s not established until Februa ry 2005. If our understanding is
correct, then it appears that al l related costs incurred prior to that time were properly
expensed. From the date that technological f easibility was establishe d in February 2005, we
would expect production costs to be capitalized if appropriate under paragraph 5 of SFAS 86.
We would also expect capitalization of comput er software costs to cease when the product
was available for general release to customer s. Maintenance and customer support costs
should be charged to expense in the manner speci fied by paragraph 6 of the above referenced
statement.
2. It appears, from your response, you intend to capita lize certain costs you incurred in fiscal
2003 and 2004 for G3CARS. If these costs were incurred prior to February 2005, it appears
to us that the costs were properly expens ed when incurred. After establishment of
technological feasibility, it w ould not be appropriate to rest ate prior fiscal periods to
ASI Enterta iment, Inc.
March 3, 2004
Page 2
subsequently capitalize costs that were previo usly considered to be R&D costs. Please
supplementally explain when and why the fi scal 2004 costs ($77,074) and the fiscal 2003
costs ($42,095) were incurred, how they were accounted for and why it is now appropriate to capitalize them.
* * * * * * * * * * *
As appropriate, please amend your filing and respond to these comments within 10
business days or tell us when you will provide us with a response. You may wish to provide us
with marked copies of the amen dment to expedite our review. Please furnish a cover letter with
your amendment that keys your responses to our comments and provides any requested
supplemental information. Detailed cover letters greatly facilitate our review. Please understand
that we may have additional co mments after reviewing your am endment and responses to our
comments.
We urge all persons who are responsible fo r the accuracy and adequa cy of the disclosure
in the filing reviewed by the staff to be certain that they have provided all information investors
require for an informed decision. Since the comp any and its management are in possession of all
facts relating to a company’s disclosure, they ar e responsible for the accuracy and adequacy of
the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of the United States.
In addition, please be advi sed that the Division of Enforcement has access to all
information you provide to the staff of the Divisi on of Corporation Finance in our review of your
filing or in response to our comments on your filing.
You may contact Amy McGann at 202- 551-3304 or Marger y Reich at 202-551-
3347 if you have questions regarding comments on the financial stat ements and related matters.
Please contact me at 202-551-3211 with any other questions.
S i n c e r e l y ,
David R. Humphrey
B r a n c h C h i e f