SEC Comment Letter for KAZIA THERAPEUTICS LTD (KZIA) (CIK 0001075880) (KZIA) — Jul 10, 2008
KAZIA THERAPEUTICS LTD (KZIA) (CIK 0001075880)
Date: July 10, 2008 · CIK: 0001075880 · Accession: 0000000000-08-034085
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 6010 Via Facsimile and U.S. Mail June 4, 2008 Mr. Christopher Naughton Managing Director Novogen Limited 140 Wicks Road North Ryde, New South Wales 2113, Australia
Re: Novogen Limited Form 20-F for fiscal year ended June 30, 2007 File No. 0-29962
Dear Mr. Naughton:
We have reviewed your May 14, 2008 re sponse to our April 11, 2008 letter and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing. Form 20-F for Fiscal Year Ended June 30, 2007
Item 18. Financial Statements
Note 24 Differences Betw een AIFRS and U.S. GAAP (iv) Minority interests, page 133 1. In your response to prior comment two, consistent with para graph 22 (c) of IAS 27, you state that minority interests consis t of (i) the amount of those minority interests at the date of original combin ation; and (ii) the minority’s share of changes in equity since the date of comb ination. However, you appear to indicate that under IFRS, minority interests are not allocated their share of profits, losses and reserves from the share purchase date. Rather they are allocated a share of all “opening” profits, losses and reserves ba sed on their percentage shareholding at year end. Please provide more specific refe rences to the IFRS technical literature that supports this accounting treatment, particularly supporting your adjustments
Mr. Christopher Naughton Novogen Limited June 4, 2008 Page 2 to minority interests and “accumulated losse s,” following the issue of new capital by a subsidiary. * * * *
Please respond to the comment within 10 business days or tell us when you will provide us with a response. Your lette r should key your response to our comment. Detailed cover letters greatly facilitate our review. Please furnish your letter on EDGAR under the form type label CORRESP.
You may contact Frank Wyman, St aff Accountant, at 202-551-3660 or Don Abbott, Senior Staff Accountant, at 202- 551-3608, if you have questions regarding the comment. In this regard, do not he sitate to contact me, at 202-551-3679.
S i n c e r e l y ,
J i m B . R o s e n b e r g Senior Assistant Chief Accountant
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Mail Stop 6010
Via Facsimile and U.S. Mail
June 4, 2008
Mr. Christopher Naughton
Managing Director
Novogen Limited
140 Wicks Road
North Ryde, New South Wales 2113, Australia
Re: Novogen Limited
Form 20-F for fiscal year ended June 30, 2007
File No. 0-29962
Dear Mr. Naughton:
We have reviewed your May 14, 2008 re sponse to our April 11, 2008 letter and
have the following comment. In our comment, we ask you to provide us with information
so we may better understand your disclosure. After reviewing the information provided,
we may raise additional comments and/or request that you amend your filing.
Form 20-F for Fiscal Year Ended June 30, 2007
Item 18. Financial Statements
Note 24 Differences Betw een AIFRS and U.S. GAAP
(iv) Minority interests, page 133
1. In your response to prior comment two, consistent with para graph 22 (c) of IAS
27, you state that minority interests consis t of (i) the amount of those minority
interests at the date of original combin ation; and (ii) the minority’s share of
changes in equity since the date of comb ination. However, you appear to indicate
that under IFRS, minority interests are not allocated their share of profits, losses
and reserves from the share purchase date. Rather they are allocated a share of all
“opening” profits, losses and reserves ba sed on their percentage shareholding at
year end. Please provide more specific refe rences to the IFRS technical literature
that supports this accounting treatment, particularly supporting your adjustments
Mr. Christopher Naughton
Novogen Limited June 4, 2008 Page 2
to minority interests and “accumulated losse s,” following the issue of new capital
by a subsidiary.
* * * *
Please respond to the comment within 10 business days or tell us when you will
provide us with a response. Your lette r should key your response to our comment.
Detailed cover letters greatly facilitate our review. Please furnish your letter on EDGAR
under the form type label CORRESP.
You may contact Frank Wyman, St aff Accountant, at 202-551-3660 or Don
Abbott, Senior Staff Accountant, at 202- 551-3608, if you have questions regarding the
comment. In this regard, do not he sitate to contact me, at 202-551-3679.
S i n c e r e l y ,
J i m B . R o s e n b e r g
Senior Assistant Chief Accountant