SEC Comment Letter for SABA SOFTWARE INC (CIK 0001070380) — Oct 7, 2005
SABA SOFTWARE INC (CIK 0001070380)
Date: Oct. 7, 2005 · CIK: 0001070380 · Accession: 0000000000-05-051701
AI Filing Summary & Sentiment
File numbers found in text: 333-125778
Referenced dates: September 16, 2005
Letter
Mail Stop 4561 Bobby Yazdani CEO and Chairman Saba Software, Inc. 2400 Bridge Parkway Redwood Shores, California 94065-1166 Form 10-K for the fiscal year ended May 31, 2005 File No. 0-30221
Re: Saba Software, Inc. Registration Statement on Form S-3/A Filed October 3, 2005 File No. 333-125778
Dear Mr. Yazdani:
We have reviewed your responses to the comments in our letter dated September 16, 2005, and have the following additional comments. Where indicated, we think you should revise your documents in response to these comments.
Form S-3, as amended on October 3, 2005 1. We note that you entered into a definitive agreement to acquire Centra Software on October 5, 2005 and that you determined that the acquisition involved a significant amount of assets to be disclosed under Item 2.01 of Form 8-K. Under Rule 3-05 and Rule 11-01 of Regulation S-X, financial statements and pro forma financial information of Centra may be required depending on the level of significance. Please tell us the calculations used to determine the significance level of this acquisition. 2. Supplement your existing disclosure to provide a recent developments section that discusses the acquisition of Centra Software. 3. Please provide updated consents of your independent public accounting firms, including the consent provided by Stout, Causey & Horning, P.A.
* * * * *
If you have any questions, please call Adam Halper, at (202) 551-3482 or Perry Hindin, at (202) 551-3444. If you require additional assistance you may contact Barbara C. Jacobs, Assistant Director at, (202) 551-3730.
Sincerely,
Barbara C. Jacobs
Assistant Director
Show Raw Text
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<TEXT>
October 7, 2005
Mail Stop 4561
Bobby Yazdani
CEO and Chairman
Saba Software, Inc.
2400 Bridge Parkway
Redwood Shores, California 94065-1166
Re: Saba Software, Inc.
Registration Statement on Form S-3/A
Filed October 3, 2005
File No. 333-125778
Form 10-K for the fiscal year ended May 31, 2005
File No. 0-30221
Dear Mr. Yazdani:
We have reviewed your responses to the comments in our letter
dated September 16, 2005, and have the following additional
comments.
Where indicated, we think you should revise your documents in
response to these comments.
Form S-3, as amended on October 3, 2005
1. We note that you entered into a definitive agreement to acquire
Centra Software on October 5, 2005 and that you determined that
the
acquisition involved a significant amount of assets to be
disclosed
under Item 2.01 of Form 8-K. Under Rule 3-05 and Rule 11-01 of
Regulation S-X, financial statements and pro forma financial
information of Centra may be required depending on the level of
significance. Please tell us the calculations used to determine
the
significance level of this acquisition.
2. Supplement your existing disclosure to provide a recent
developments section that discusses the acquisition of Centra
Software.
3. Please provide updated consents of your independent public
accounting firms, including the consent provided by Stout, Causey
&
Horning, P.A.
* * * * *
If you have any questions, please call Adam Halper, at (202)
551-3482 or Perry Hindin, at (202) 551-3444. If you require
additional assistance you may contact Barbara C. Jacobs, Assistant
Director at, (202) 551-3730.
Sincerely,
Barbara C. Jacobs
Assistant Director
cc: Via Facsimile
Peter E. Williams III, Chief Financial Officer
Fax: (650) 581-2599
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Bobby Yazdani
Saba Software, Inc.
October 7, 2005
Page 1
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