SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Comment Letter for AXON ENTERPRISE, INC. (AXON) (CIK 0001069183) (AXON) — Apr 22, 2005

AXON ENTERPRISE, INC. (AXON) (CIK 0001069183)
Date: April 22, 2005 · CIK: 0001069183 · Accession: 0000000000-05-019703

AI Filing Summary & Sentiment

Date
April 21, 2005
Author
John Cash
Form
UPLOAD
Company
AXON ENTERPRISE, INC. (AXON) (CIK 0001069183)

Letter

April 21, 2005 via U.S. mail and facsimile Mr. Daniel M. Behrendt, Chief Financial Officer Taser International, Inc. 7860 E. McClain Drive, Suite 2 Scottsdale, Arizona 85260

Re: Item 4.02 Form 8-K Filed: April 20, 2005 File No. 1-16391

Dear Mr. Behrendt:

We have reviewed your Item 4.02 Form 8-K for compliance with the form requirements and have the following comments. 1. You have disclosed that you intend to file restated financial statements. However, you have not indicated when you intend to do so. Please tell us when you intend to file restated financial statements. We may have further comments after you file the restated financial statements.

We remind you that when you file your restated Form 10-KSB you should appropriately address the following: * an explanatory paragraph in the reissued audit opinion, * full compliance with APB 20, paragraphs 36 and 37, * fully update all affected portions of the document, including MD&A * updated Item 8A. disclosures should include the following: o a discussion of the restatement and the facts and circumstances surrounding it, o how the restatement impacted the CEO and CFO`s original conclusions regarding the effectiveness of their disclosure controls and procedures, o changes to internal controls over financial reporting, and o anticipated changes to disclosure controls and procedures and/or internal controls over financial reporting to prevent future misstatements of a similar nature. Refer to Items 307 and 308(c) of Regulation S-B. * include all updated certifications.

* * * *

Please respond to these comments within 5 business days, or tell us when you will provide us with a response. Please provide us with a supplemental response letter that keys your responses to our comments and provides any requested supplemental information. Detailed letters greatly facilitate our review. Please file your supplemental response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments.

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.

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 disclosure in their filings; * 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 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 our review of your filing or in response to our comments on your filing.

If you have any questions regarding these comments, please direct them to Bret Johnson, Staff Accountant, at (202) 824-5478 or, in his absence, to the undersigned at (202) 824-5373.

Sincerely,
John Cash
Accounting Branch Chief
??

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      April 21, 2005

via U.S. mail and facsimile

Mr. Daniel M. Behrendt, Chief Financial Officer
Taser International, Inc.
7860 E. McClain Drive, Suite 2
Scottsdale, Arizona 85260

	Re:	Item 4.02 Form 8-K
	Filed:	April 20, 2005
	File No. 1-16391

Dear Mr. Behrendt:

	We have reviewed your Item 4.02 Form 8-K for compliance with
the
form requirements and have the following comments.
1. You have disclosed that you intend to file restated financial
statements.  However, you have not indicated when you intend to do
so.  Please tell us when you intend to file restated financial
statements.  We may have further comments after you file the
restated
financial statements.

We remind you that when you file your restated Form 10-KSB you
should
appropriately address the following:
* an explanatory paragraph in the reissued audit opinion,
* full compliance with APB 20, paragraphs 36 and 37,
* fully update all affected portions of the document, including
MD&A
* updated Item 8A. disclosures should include the following:
o a discussion of the restatement and the facts and circumstances
surrounding it,
o how the restatement impacted the CEO and CFO`s original
conclusions
regarding the effectiveness of their disclosure controls and
procedures,
o changes to internal controls over financial reporting, and
o anticipated changes to disclosure controls and procedures and/or
internal controls over financial reporting to prevent future
misstatements of a similar nature.
Refer to Items 307 and 308(c) of Regulation S-B.
* include all updated certifications.

*    *    *    *

      Please respond to these comments within 5 business days, or
tell us when you will provide us with a response.  Please provide
us
with a supplemental response letter that keys your responses to
our
comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

      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.

	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
disclosure in their filings;
* 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 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 our review of your filing
or
in response to our comments on your filing.

	If you have any questions regarding these comments, please
direct them to Bret Johnson, Staff Accountant, at (202) 824-5478
or,
in his absence, to the undersigned at (202) 824-5373.

							Sincerely,

							John Cash
							Accounting Branch Chief
??

??

??

??

Mr. Daniel Behrendt
April 21, 2005
Page 1 of 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>