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SEC Company Response from O2MICRO INTERNATIONAL LTD (CIK 0001095348) — Sep 8, 2005

O2MICRO INTERNATIONAL LTD (CIK 0001095348)
Date: Sept. 8, 2005 · CIK: 0001095348 · Accession: 0001193125-05-182334

AI Filing Summary & Sentiment

File numbers found in text: 000-30910

Date
September 8, 2005
Author
/s/ Justin L. Bastian
Form
CORRESP
Company
O2MICRO INTERNATIONAL LTD (CIK 0001095348)

Letter

Division of Corporation Finance United States Securities and Exchange Commission Re: O2Micro International Limited Comments on Form 20-F for the Year Ended December 31, 2004 File No. 000-30910

Dear Ms. Harkins:

On behalf of our client, O2Micro International Limited (the “Company”) and in connection to the Company’s response to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter of July 27, 2005, which response was filed with the Commission on August 31, 2005, the Company acknowledges that:

(i) the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

(ii) 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

(iii) the Company may not assert Staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States.

Ms. Tara L. Harkins

September 8, 2005

Page Two

Please call me at the number above if you have any questions.

Very truly yours,
/s/ Justin L. Bastian

Show Raw Text
CORRESP
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filename1.htm

Letter of Correspondence

 755 PAGE MILL ROAD

 PALO ALTO

 CALIFORNIA 94304-1018

 TELEPHONE: 650.813.5600

 FACSIMILE: 650.494.0792

 WWW.MOFO.COM

 MORRISON & FOERSTER LLP

 NEW YORK, SAN FRANCISCO,

 LOS ANGELES, PALO ALTO,

 SAN DIEGO, WASHINGTON, D.C.

 DENVER, NORTHERN VIRGINIA,

 ORANGE COUNTY, SACRAMENTO,

 WALNUT CREEK, CENTURY
CITY

 TOKYO, LONDON,
BEIJING,

 SHANGHAI, HONG KONG,

 SINGAPORE, BRUSSELS

September 8, 2005

 Writer’s Direct Contact

 (650) 813-5641

JBastian@mofo.com

 By Telefacsimile and Mail

 Ms. Tara L. Harkins

 Division of Corporation Finance

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:

O2Micro International Limited

Comments on Form 20-F for the Year Ended December 31, 2004

File No. 000-30910

 Dear Ms. Harkins:

 On behalf of our client, O2Micro International Limited (the “Company”) and in
connection to the Company’s response to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter of July 27, 2005, which response was filed with the
Commission on August 31, 2005, the Company acknowledges that:

 (i) the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 (ii) 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

 (iii) the Company may not assert Staff comments
as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States.

 Ms. Tara L. Harkins

 September 8, 2005

 Page Two

 Please call me at the number above if you have any questions.

 Very truly yours,

 /s/ Justin L. Bastian

 cc:    Mr. Sterling Du, O2Micro International Limited