SEC Comment Letter for INSWEB CORP (CIK 0001077370) — Apr 21, 2005
INSWEB CORP (CIK 0001077370)
Date: April 21, 2005 · CIK: 0001077370 · Accession: 0000000000-05-019609
AI Filing Summary & Sentiment
Referenced dates: April 18, 2005
Letter
April 21, 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 response letter dated April 18, 2005 and have the following additional comment. As previously stated, this comment should be addressed in all future filings with the Commission.
Management`s Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 25
1. We have read your proposed disclosure in response to our comment. While your proposed disclosure appears to provide a discussion of your ability to meet cash requirements on a long-term basis, it does not appear to provide a discussion of the underlying drivers that impact changes in cash flow and/or working capital. In a supplemental response, please confirm to us that you will expand your proposed disclosure in all future filings to include a discussion of the underlying drivers impacting changes in cash flow and/or working capital. Refer to Item 303 of Regulation S-K and 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.
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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<TEXT>
April 21, 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 response letter dated April 18, 2005
and
have the following additional comment. As previously stated, this
comment should be addressed in all future filings with the
Commission.
Management`s Discussion and Analysis of Financial Condition and
Results of Operations
Liquidity and Capital Resources, page 25
1. We have read your proposed disclosure in response to our
comment.
While your proposed disclosure appears to provide a discussion of
your ability to meet cash requirements on a long-term basis, it
does
not appear to provide a discussion of the underlying drivers that
impact changes in cash flow and/or working capital. In a
supplemental response, please confirm to us that you will expand
your
proposed disclosure in all future filings to include a discussion
of
the underlying drivers impacting changes in cash flow and/or
working
capital. Refer to Item 303 of Regulation S-K and 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.
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 21, 2005
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