SEC Comment Letter for SABA SOFTWARE INC (CIK 0001070380) — Jan 12, 2005
SABA SOFTWARE INC (CIK 0001070380)
Date: Jan. 12, 2005 · CIK: 0001070380 · Accession: 0000000000-05-002097
AI Filing Summary & Sentiment
File numbers found in text: 333-118226
Referenced dates: November 30, 2004
Letter
December 9, 2004 Bobby Yazdani CEO and Chairman Saba Software, Inc. 2400 Bridge Parkway Redwood Shores, California 94065-1166 Form 10-K for fiscal year ended May 31, 2004, as amended Form 10-Q for the quarterly period ended August 31, 2004 File No. 0-30221
RE: Saba Software, Inc. Amendment No. 2 to Form S-3 Filed October 27, 2004 File No. 333-118226
Dear Mr. Yazdani:
We have reviewed your response letter dated November 30, and have the following additional comments. Where indicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Form 10-K for fiscal year ended May 31, 2004 1. We have reviewed your supplemental response to prior comment 3. In this regard, please tell us how and in what sections of future filings your disclosures will address the differences between your hosting services and your application service provider offerings. Please also include reference(s) to the appropriate revenue recognition literature that supports your treatment of these transactions. For example, your hosting services involve multiple elements and your revenue
recognition policy should clarify what these elements are (e.g., software license and hosting services) as well as the accounting literature you relied upon for the treatment of these elements.
* * * *
As appropriate, please amend your filings in response to these comments. You may wish to provide us with marked copies of the amendment 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 file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Patrick Gilmore, Staff Accountant, at (202) 824-5355 or Craig Wilson, Senior Assistant Chief Accountant, at (202) 942-2949, if you have questions regarding comments on the financial statements and related matters. Please contact Robert D. Bell, Staff Attorney, at (202) 942-1953, or me at (202) 942-1990 with any other questions.
Sincerely,
Barbara C. Jacobs
Assistant Director
Office of Computers and Online
Services
Show Raw Text
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<TEXT>
Mail Stop 4-6
December 9, 2004
Bobby Yazdani
CEO and Chairman
Saba Software, Inc.
2400 Bridge Parkway
Redwood Shores, California 94065-1166
RE: Saba Software, Inc.
Amendment No. 2 to Form S-3
Filed October 27, 2004
File No. 333-118226
Form 10-K for fiscal year ended May 31, 2004, as amended
Form 10-Q for the quarterly period ended August 31, 2004
File No. 0-30221
Dear Mr. Yazdani:
We have reviewed your response letter dated November 30,
2004
and have the following additional comments. Where indicated, we
think you should revise your documents in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary. Please be
as
detailed as necessary in your explanation. In some of our
comments,
we may ask you to provide us with supplemental information so we
may
better understand your disclosure. After reviewing this
information,
we may or may not raise additional comments.
Form 10-K for fiscal year ended May 31, 2004
1. We have reviewed your supplemental response to prior comment 3.
In this regard, please tell us how and in what sections of future
filings your disclosures will address the differences between your
hosting services and your application service provider offerings.
Please also include reference(s) to the appropriate revenue
recognition literature that supports your treatment of these
transactions. For example, your hosting services involve multiple
elements and your revenue
recognition policy should clarify what these elements are (e.g.,
software license and hosting services) as well as the accounting
literature you relied upon for the treatment of these elements.
* * * *
As appropriate, please amend your filings in response to
these
comments. You may wish to provide us with marked copies of the
amendment 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 file your cover letter on
EDGAR. Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.
You may contact Patrick Gilmore, Staff Accountant, at (202)
824-5355 or Craig Wilson, Senior Assistant Chief Accountant, at
(202)
942-2949, if you have questions regarding comments on the
financial
statements and related matters. Please contact Robert D. Bell,
Staff
Attorney, at (202) 942-1953, or me at (202) 942-1990 with any
other
questions.
Sincerely,
Barbara C. Jacobs
Assistant Director
Office of Computers and Online
Services
cc: James R. Tanenbaum, Esq.
Morrison & Foerster LLP
Fax (212) 468-7900
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Mr. Bobby Yazdani
Saba Software, Inc.
Form S-3; File No. 333-118226
December 9, 2004
Page 2 of 2
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