SEC Comment Letter for REGISTER COM INC (CIK 0001091284) — Jul 11, 2005
REGISTER COM INC (CIK 0001091284)
Date: July 11, 2005 · CIK: 0001091284 · Accession: 0000000000-05-035272
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Mail Stop 4561
July 11, 2005
Ms. Roni A. Jacobson
General Counsel and Secretary
Register.Com, Inc.
575 Eighth Avenue, 8th Floor
New York, NY 10018
RE: Register.Com, Inc.
Form 8-K
Filed June 6, 2005
File No. 0-29739
Dear Ms. Jacobson:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. 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 comments or on any other
aspect
of our review. Feel free to call me at the telephone number
listed
at the end of this letter.
Form 8-K filed June 6, 2005
1. Provide us with any letter or written communication to and from
the former accountants regarding any disagreements or reportable
events to management or the Audit Committee.
2. Please provide us with a schedule of your fiscal year end
fourth
quarter adjustments to close the books, or adjustments recorded in
connection with or as a result of the audit. Clearly explain the
reason for each adjustment. For each adjustment, show us the
impact on pre-tax net loss. Quantify the net effect of all
adjustments on pre-tax net income (loss). Also, tell us why none
of
the adjustments relate to prior period. Explain in detail why you
believe the timing of each adjustment is appropriate.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed investment 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 filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; 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 filing or in
response to our comments on your filing.
Please provide the supplemental information requested above
within five business days from the date of this letter. The
supplemental information should be filed as correspondence on
EDGAR.
Any questions regarding the above should be directed to me
at
(202) 551-3469.
Sincerely,
Thomas Flinn
Staff Accountant
Ms. Roni A. Jacobson
Register.Com, Inc.
July 11, 2005
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