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SEC Comment Letter for DIGITAS INC (CIK 0001100885) — Dec 1, 2005

DIGITAS INC (CIK 0001100885)
Date: Dec. 1, 2005 · CIK: 0001100885 · Accession: 0000000000-05-060250

AI Filing Summary & Sentiment

File numbers found in text: 000-29723

Date
November 30, 2005
Author
Linda Van Doorn
Form
UPLOAD
Company
DIGITAS INC (CIK 0001100885)

Letter

November 30, 2005 VIA USMAIL and FAX (617) 867 - 1111 Mr. Brian K. Roberts Chief Financial Officer Digitas, Inc. The Prudential Tower 800 Boylston Street Boston, Massachusetts 02199

Re: Digitas, Inc. Form 10-K for the year ended 12/31/2004 Filed 3/15/2005 File Nos. 000-29723

Dear Mr. Brian K. Roberts:

We have reviewed your filing and have the following comment. We have limited our review to only the issues addressed below and will make no further review of your document. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934.

Where indicated, we think you should revise your document in response to this comment. 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 our comment, we may ask you to provide us with 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 disclosures 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 THE YEAR ENDED MARCH 31, 2005

Financial Statements and Notes

Note 14. Commitments and Contingencies, pages F-26 - F-27

1. We note that Modem Media is a guarantor for the office lease obligations of CentrPoint, Inc. Tell us how you considered paragraphs 5, 14, and 15 of FIN 46 (R) in determining whether CentrPoint Inc. represented a variable interest entity and whether you were the primary beneficiary.

* * * *

As appropriate, respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that key your response to our comment and provide any requested information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an informed 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 comment, 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 filings;

* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; 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 comment on your filing.

You may contact Wilson K. Lee, at (202) 551-3468 or me, at (202) 551-3498 if you have questions.

Sincerely,
Linda Van Doorn
Senior Assistant Chief Accountant

Show Raw Text
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<TEXT>

Mail Stop 4561

          November 30, 2005

      VIA USMAIL and FAX (617) 867 - 1111

Mr. Brian K. Roberts
Chief Financial Officer
Digitas, Inc.
The Prudential Tower
800 Boylston Street
Boston, Massachusetts 02199

      Re:	Digitas, Inc.
		Form 10-K for the year ended 12/31/2004
      Filed 3/15/2005
      File Nos. 000-29723

Dear Mr. Brian K. Roberts:

      We have reviewed your filing and have the following comment.
We have limited our review to only the issues addressed below and
will make no further review of your document.  As such, all
persons
who are responsible for the adequacy and accuracy of the
disclosure
are urged to be certain that they have included all information
required pursuant to the Securities Exchange Act of 1934.

      Where indicated, we think you should revise your document in
response to this comment.  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 our comment, we may ask you to provide us with 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 disclosures 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 THE YEAR ENDED MARCH 31, 2005

Financial Statements and Notes

Note 14.  Commitments and Contingencies, pages F-26 - F-27

1. We note that Modem Media is a guarantor for the office lease
obligations of CentrPoint, Inc.   Tell us how you considered
paragraphs 5, 14, and 15 of FIN 46 (R) in determining whether
CentrPoint Inc. represented a variable interest entity and whether
you were the primary beneficiary.

*    *    *    *

      As appropriate, respond to this comment within 10 business
days
or tell us when you will provide us with a response.  Please
furnish
a cover letter that key your response to our comment and provide
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please file your cover letter on EDGAR.  Please
understand
that we may have additional comments after reviewing your response
to
our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 comment, 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 comment on your filing.

	You may contact Wilson K. Lee, at (202) 551-3468 or me, at
(202)
551-3498 if you have questions.

							    Sincerely,

    Linda Van Doorn
    Senior Assistant Chief Accountant

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Brian K. Roberts
Digitas, Inc.
November 30, 2005
Page 1

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