SEC Company Response from ARTISTDIRECT INC (CIK 0001095079) — Sep 27, 2005
ARTISTDIRECT INC (CIK 0001095079)
Date: Sept. 27, 2005 · CIK: 0001095079 · Accession: 0000950137-05-011777
AI Filing Summary & Sentiment
Referenced dates: September 12, 2005
Letter
VIA EDGAR AND FACSIMILE Securities and Exchange Commission Division of Corporation Finance Attention: ARTISTdirect, Inc. (the “Company”) Schedule 14C Information Statement File No. 0-30063 Filed August 17, 2005
Dear Ms. Mittelman:
The purpose of this correspondence is to confirm our discussion on Monday, September 26, 2005. The staff of the Securities and Exchange Commission (the “Staff”) issued a comment letter addressed to Jonathan Diamond, President of the Company, dated September 2, 2005 (the “Comment Letter”), with respect to the above-referenced filing. We filed a response on behalf of the Company to the Comment Letter dated September 12, 2005, which addressed the Staff’s concerns (the “Response Letter”). Capitalized terms used, but not defined, in this letter shall have the meanings given to them in the Information Statement.
It is our understanding that the Staff will not be issuing follow-up correspondence with respect to the Response Letter. Further, it is our understanding that so long as the Company provides the disclosures set forth in item number 1 of the Response Letter, the Information Statement will not be subject to further review by the Staff.
We anticipate filing Amendment No. 1 to the preliminary Information Statement within the next five (5) business days. The definitive Information Statement will then be filed with the Securities and Exchange Commission (the “SEC”) and distributed to the Company’s stockholders at least ten (10) calendar days thereafter, but in no event prior to the filing with the SEC of the Form 8-K/A by the Company which shall include a copy of the audited financial statements of MediaDefender and unaudited pro forma financial information.
If this correspondence does not set forth your understanding of our discussion, please contact me immediately. Should you have any questions or concerns, please do not hesitate to contact the undersigned or David I. Sunkin, Esq. at 213.620.1780.
Sincerely,
/s/ Kristy D. Palmquist
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CORRESP
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corresp
September 27, 2005
VIA EDGAR AND FACSIMILE
Facsimile No. (202) 772-9209
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0308
Attention:
Charito A. Mittelman, Esq.
Re:
ARTISTdirect, Inc. (the “Company”)
Schedule 14C Information Statement
File No. 0-30063
Filed August 17, 2005
Dear Ms. Mittelman:
The purpose of this correspondence is to confirm our discussion on Monday, September 26, 2005.
The staff of the Securities and Exchange Commission (the “Staff”) issued a comment letter
addressed to Jonathan Diamond, President of the Company, dated September 2, 2005 (the “Comment
Letter”), with respect to the above-referenced filing. We filed a response on behalf of the
Company to the Comment Letter dated September 12, 2005, which addressed the Staff’s concerns (the
“Response Letter”). Capitalized terms used, but not defined, in this letter shall have the
meanings given to them in the Information Statement.
It is our understanding that the Staff will not be issuing follow-up correspondence with
respect to the Response Letter. Further, it is our understanding that so long as the Company
provides the disclosures set forth in item number 1 of the Response Letter, the Information
Statement will not be subject to further review by the Staff.
We anticipate filing Amendment No. 1 to the preliminary Information Statement within the next
five (5) business days. The definitive Information Statement will then be filed with the
Securities and Exchange Commission (the “SEC”) and distributed to the Company’s stockholders at
least ten (10) calendar days thereafter, but in no event prior to the filing with the SEC of the
Form 8-K/A by the Company which shall include a copy of the audited financial statements of
MediaDefender and unaudited pro forma financial information.
If this correspondence does not set forth your understanding of our discussion, please contact
me immediately. Should you have any questions or concerns, please do not hesitate to contact the
undersigned or David I. Sunkin, Esq. at 213.620.1780.
Sincerely,
/s/ Kristy D. Palmquist
Kristy D. Palmquist, Esq.
on behalf of Sheppard Mullin Richter &
Hampton LLP
cc:
David I. Sunkin, Esq., Sheppard Mullin Richter & Hampton LLP
Robert N. Weingarten, Chief Financial Officer, ARTISTdirect, Inc.