SEC Comment Letter for INSWEB CORP (CIK 0001077370) — Apr 7, 2005
INSWEB CORP (CIK 0001077370)
Date: April 7, 2005 · CIK: 0001077370 · Accession: 0000000000-05-016895
AI Filing Summary & Sentiment
Letter
April 7, 2005 Mail Stop 0409 Mr. William D. Griffin Chief Financial Officer InsWeb Corporation 11290 Pyrites Way Gold River, CA 95670
Re: InsWeb Corporation Form 10-K for the year ended December 31, 2004 File No. 0-26083
Dear Mr. Griffin:
We have reviewed your filing and have the following comment. We have limited our review to only the issue addressed below and will make no further review of your document. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934.
Where indicated, we think you should revise your document in response to this comment in future filings. 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.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Management`s Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 25
1. Based upon our review of your liquidity discussion, we note that your disclosure does not appear to provide a discussion of your ability to meet cash requirements on a long-term basis or the underlying drivers impacting changes in cash flow and/or working capital. Considering your historical operating losses and negative cash flows, please confirm to us that you will revise your disclosure in all future filings pursuant to the requirements of Item 303 of Regulation S-K and the guidance of FR 72, Commission Guidance Regarding Management`s Discussion and Analysis of Financial Condition and Results of Operations.
* * * *
As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your proposed revisions that keys your response to our comment 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 response to our comment.
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 the 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 filings; 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 filings or in response to our comments on your filings.
You may contact Rachel Zablow, Staff Accountant, at (202) 824- 5336 or the undersigned at (202) 824-5222 if you have questions.
Sincerely,
Steven Jacobs
Accounting Branch Chief
Show Raw Text
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April 7, 2005
Mail Stop 0409
Mr. William D. Griffin
Chief Financial Officer
InsWeb Corporation
11290 Pyrites Way
Gold River, CA 95670
Re: InsWeb Corporation
Form 10-K for the year ended December 31, 2004
File No. 0-26083
Dear Mr. Griffin:
We have reviewed your filing and have the following comment.
We have limited our review to only the issue addressed below and
will
make no further review of your document. As such, all persons who
are responsible for the adequacy and accuracy of the disclosure
are
urged to be certain that they have included all information
required
pursuant to the Securities Exchange Act of 1934.
Where indicated, we think you should revise your document in
response to this comment in future filings. 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.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comment or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Management`s Discussion and Analysis of Financial Condition and
Results of Operations
Liquidity and Capital Resources, page 25
1. Based upon our review of your liquidity discussion, we note
that
your disclosure does not appear to provide a discussion of your
ability to meet cash requirements on a long-term basis or the
underlying drivers impacting changes in cash flow and/or working
capital. Considering your historical operating losses and
negative
cash flows, please confirm to us that you will revise your
disclosure
in all future filings pursuant to the requirements of Item 303 of
Regulation S-K and the guidance of FR 72, Commission Guidance
Regarding Management`s Discussion and Analysis of Financial
Condition
and Results of Operations.
* * * *
As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your proposed revisions that
keys
your response to our comment 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 response to our
comment.
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 the 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 filings; 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 filings or
in
response to our comments on your filings.
You may contact Rachel Zablow, Staff Accountant, at (202)
824-
5336 or the undersigned at (202) 824-5222 if you have questions.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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InsWeb Corporation
April 7, 2005
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