SEC Comment Letter for INFORTE CORP (CIK 0001099944) — Oct 31, 2005
INFORTE CORP (CIK 0001099944)
Date: Oct. 31, 2005 · CIK: 0001099944 · Accession: 0000000000-05-055136
AI Filing Summary & Sentiment
Referenced dates: August 26, 2005
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Room 4561
October 25, 2005
Mr. Nick Heyes
Chief Financial Officer and Secretary
Inforte Corp.
150 North Michigan Avenue Suite 3400
Chicago, IL 60601
Re: Inforte Corp.
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 31, 2005
Form 8-K Filed April 22, 2005
Form 8-K Filed July 28, 2005
File No. 0-29239
Dear Mr. Heyes,
We have reviewed your response letter dated August 26, 2005
and
have the following additional comments. We may ask you to provide
us
with supplemental information so we may better understand your
disclosure. Please be as detailed as necessary in your
explanation.
After reviewing this information, we may 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 comment or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-K for Fiscal Year Ended December 31, 2004
Item 6. Selected Financial Data, page 13
1. We have read your response to prior comment 1 and we do not
believe that you have adequately supported excluding any
disclosure
related to the reimbursable expenses. Item 303 of Regulation S-K
requires that you describe significant components of revenues or
expenses that should be described in order to understand your
results
of operations. We believe that these reimbursable expenses are
material to an understanding of your revenues, expenses and, in
particular, your margins. Accordingly, we believe that discussion
of
the impact of these items is required. Further, we believe that
the
nature of the reimbursements revenue is not such that it may be
excluded from your Selected Financial Data under Item 301 of
Regulation S-K. In addition, "net revenue" and "operating expenses
before reimbursements" appear to be non-GAAP financial measures as
defined within Item 10 of Regulation S-K.
Liquidity and Capital Resources, page 20
2. We have read your responses to prior comments 3 and 10 and do
not
believe that you have adequately supported your use of "cash and
marketable securities per common share."
Consolidated Financial Statements
Consolidated Statements of Operations, page 28
3. Please direct us to the guidance that explicitly requires that
your income statement include "several extra lines." In addition,
refer us to the literature that relieves you of your obligation to
comply with Item 302(a)(1) of Regulation S-K under the
circumstances
that you describe in your response to prior comment 5.
Note 2. Significant Accounting Policies
Revenue Recognition, page 32
4. Please confirm to us that you will include the additional
disclosure provided in your response to prior comment 6 in your
future filings.
Form 8-K Filed April 22, 2005
5. We have read your response to prior comment 8 and do not agree
that you achieved the appropriate disclosure through the
presentation
of the accompanying financial tables. Please supplement your
response
by providing us with proposed revisions using the second paragraph
of
your first quarter 2005 earnings release as an example.
6. Please address the following related to your response to prior
comment 9 and your non-GAAP disclosures:
* Your "reconciliation" appears to include a number of non-GAAP
measures such as non-GAAP income before income tax, non-GAAP
income
tax expense and non-GAAP net income for which you have not
included
specific, meaningful disclosures as required by Item
10(e)(1)(i)(B),
(C) and (D) of Regulation S-K; and
* Percentages calculated using a numerator that has been adjusted
or
a denominator that represents "net revenue" also appear to be
separate non-GAAP measures that require the specific disclosures
described above.
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please submit all correspondence and supplemental materials on
EDGAR
as required by Rule 101 of Regulation S-T. You may wish to
provide
us with marked copies of any amendment to expedite our review.
Please furnish a cover letter with any amendment that keys your
responses to our comments and provides any requested information.
Detailed cover letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing
any
amendment and your responses to our comments.
You may contact Mark Kronforst at (202) 551-3451 or me at
(202)
551-3489 if you have any questions regarding these comments.
Very truly yours,
Brad Skinner
Accounting Branch Chief
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Nick Heyes
Inforte Corp.
October 25, 2005
Page 3
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