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SEC Company Response from ASI ENTERTAINMENT INC (CIK 0001067873) — May 19, 2005

ASI ENTERTAINMENT INC (CIK 0001067873)
Date: May 19, 2005 · CIK: 0001067873 · Accession: 0001067873-05-000010

AI Filing Summary & Sentiment

Referenced dates: May 9, 2005

Date
May 19, 2005
Author
Branch Chief
Form
CORRESP
Company
ASI ENTERTAINMENT INC (CIK 0001067873)

Letter

ASI Entertainment, Inc. 1/12 Candlebark Crt., Research, Victoria, 3095, Australia Telephone : +61.3.9437 1028 . E-mail: info@asieinc.com May 19, 2005 Mr D. R. Humphrey Branch Chief Division of Corporate Finance United States Securities and Exchange Commission Washington, D.C., 20549

Re: Commission File Number: 0-27881

Dear Mr. Humphrey

In response to your letter dated May 9, 2005, we respond as follows:

We understand from your comments 1. and 2., that the expensing of costs for development of the G3CARS was correct and that we have mistaken your earlier comments that we should capitalize the development costs retrospectively. The costs incurred in 2004 ($77,074) and 2003 ($42,095) were undertaken to establish technological feasibility, and thus were appropriately expensed under paragraph 3 of SFAS 86. Accordingly, we will not capitalize these development costs. Pursuant to paragraph 5 of SFAS 86, we will capitalize the costs of producing product masters subsequent to February 2005, but will cease capitalizing costs when the G3CARS product is available for general release to customers. Also upon availability of the G3CARS for general release, we will expense maintenance and support costs when related revenue is recognized or when those costs are incurred, whichever comes first.

Please contact me should you have further questions.

Yours sincerely

/s/ Philip Shiels

Philip Shiels Chief Financial Officer

Show Raw Text
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<TEXT>

ASI Entertainment, Inc.
1/12 Candlebark Crt.,  Research,  Victoria,  3095,  Australia
Telephone : +61.3.9437 1028 . E-mail: info@asieinc.com

May 19, 2005

Mr D. R. Humphrey
Branch Chief
Division of Corporate Finance
United States Securities and Exchange Commission
Washington, D.C., 20549

Dear Mr. Humphrey

Re:	Commission File Number: 0-27881

In response to your letter dated May 9, 2005, we respond as follows:

We  understand from your comments 1. and 2., that the expensing of costs for
development of the G3CARS was correct and that we have mistaken your earlier
comments that we should capitalize the development costs retrospectively.  The
costs incurred in 2004 ($77,074) and 2003 ($42,095) were undertaken to
establish technological feasibility, and thus were appropriately expensed
under paragraph 3 of SFAS 86.  Accordingly, we will not capitalize these
development costs.  Pursuant to paragraph 5 of SFAS 86, we will capitalize the
costs of producing product masters subsequent to February 2005, but will
cease capitalizing costs when the G3CARS product is available for general
release to customers.  Also upon availability of the G3CARS for general
release, we will expense maintenance and support costs when related revenue is
recognized or when those costs are incurred, whichever comes first.

Please contact me should you have further questions.

Yours sincerely

/s/ Philip Shiels

Philip Shiels
Chief Financial Officer

</TEXT>
</DOCUMENT>