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SEC Company Response from PORTAL SOFTWARE INC (CIK 0001080306) — Dec 15, 2005

PORTAL SOFTWARE INC (CIK 0001080306)
Date: Dec. 15, 2005 · CIK: 0001080306 · Accession: 0001193125-05-243478

AI Filing Summary & Sentiment

File numbers found in text: 000-25829

Date
December 15, 2005
Author
/s/ Larry Bercovich
Form
CORRESP
Company
PORTAL SOFTWARE INC (CIK 0001080306)

Letter

Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549 Form 8-K filed November 28, File No. 000-25829

RE: Portal Software, Inc.

Dear Mr. White,

This letter is to confirm the facts of the telephone conversation you had with Amy Pearce regarding Portal Software, Inc. (the “Company”). Discussion was in regards to the response time required to amend the above referenced Form 8-K (the “Amendment”). I received on December 13, 2005 by U.S. mail the letter from the SEC executed by Mr. Krikorian dated December 2, 2005 and post marked December 8, 2005. Mr. Krikorian’s letter states that the Company has ten (10) business days to file its Amendment. Based upon the conversation you had with Ms. Pearce, the ten business day rule technically runs from the date of the letter. However, because of lapse in delivery time, you have allowed for the 10 business day clock to begin running on December 13, 2005. We will file the Amendment by Monday, December 26, 2005.

If you have any questions or comments, please contact me at (408) 572-2904.

Best regards,
/s/ Larry Bercovich

Show Raw Text
CORRESP
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filename1.htm

Correspondence Letter

 Via FedEx and Edgar

 December 15, 2005

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

RE:
Portal Software, Inc.

 Form 8-K filed November 28,
2005

 File No. 000-25829

 Dear Mr. White,

 This letter is to confirm the facts of the telephone conversation you had with Amy Pearce regarding Portal Software, Inc. (the “Company”). Discussion was in regards to the response time required to amend the
above referenced Form 8-K (the “Amendment”). I received on December 13, 2005 by U.S. mail the letter from the SEC executed by Mr. Krikorian dated December 2, 2005 and post marked December 8, 2005.
Mr. Krikorian’s letter states that the Company has ten (10) business days to file its Amendment. Based upon the conversation you had with Ms. Pearce, the ten business day rule technically runs from the date of the letter.
However, because of lapse in delivery time, you have allowed for the 10 business day clock to begin running on December 13, 2005. We will file the Amendment by Monday, December 26, 2005.

 If you have any questions or comments, please contact me at
(408) 572-2904.

 Best regards,

 /s/ Larry Bercovich

 Larry Bercovich

 SVP, General Counsel and Secretary