SEC Comment Letter for CAMTEK LTD (CAMT) (CIK 0001109138) (CAMT) — Sep 17, 2009
CAMTEK LTD (CAMT) (CIK 0001109138)
Date: Sept. 17, 2009 · CIK: 0001109138 · Accession: 0000000000-09-051897
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-30664
Letter
Re: Camtek, Ltd. Forms 20-F for Fiscal Years Ended December 31, 2006, and 2008 Filed on June 29, 2007 and April 8, 2009 File No. 000-30664 Dear Ms. Rosenzweig: We have reviewed your filings and have the following comments. Where indicated, we think you should revise your future filings 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. Af ter reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our re view 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 us at the telephone numbers listed at the end of this letter.
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549
DIVISION OF CORPORATION FINANCE Mail Stop 3030
September 17, 2009 VIA U.S. MAIL and FACSIMILE: (972) (4) 604-8300
Ms. Mira Rosenzweig Chief Financial Officer Camtek, Ltd. Ramat Gavriel Industrial Zone P.O. Box 544 Migdal Ha’Emek, Israel
Ms. Mira Rosenzweig Camtek, Ltd. September 17, 2009 Page 2 Form 20-F for the Year Ended December 31, 2006
Item 18. Consolidated Financial Statements
1. We refer to your response to prior comm ent 1. Please also respond with respect to the Form 20-F for the year ended D ecember 31, 2006. That filing also does not appear to include audit reports covering each annual period presented. Also, note that under Exchange Act Rule 12b-15 when you amend a filing the amendment must include the entire text of the amended item(s) and currently dated certifications. Form 20-F for the Year Ended December 31, 2008
Note 5 - Inventories, page F-16
2. We note your response to our prior comment 6. In future filings please expand your disclosures relating to short-term and long-term inventory to address the substance of your response to our comment.
*****
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Pl ease furnish a cover letter 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 your amendmen t and responses to our comments. You may contact Jong Hwang at (202) 551-3327 or me at (202) 551-3605 if you have questions about these comments. In this regard, please do not hesitate to contact Brian Cascio, Branch Chief, at ( 202) 551-3676 with any other questions.
Sincerely,
Gary Todd Senior Review Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE Mail Stop 3030
September 17, 2009
VIA U.S. MAIL and FACSIMILE: (972) (4) 604-8300
Ms. Mira Rosenzweig Chief Financial Officer Camtek, Ltd. Ramat Gavriel Industrial Zone P.O. Box 544 Migdal Ha’Emek, Israel
Re: Camtek, Ltd.
Forms 20-F for Fiscal Years Ended December 31, 2006, and 2008
Filed on June 29, 2007 and April 8, 2009
File No. 000-30664
Dear Ms. Rosenzweig:
We have reviewed your filings and have the following comments. Where
indicated, we think you should revise your future filings 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. Af ter reviewing this information, we may or
may not raise additional comments.
Please understand that the purpose of our re view 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 us at the telephone numbers listed at the end of this letter.
Ms. Mira Rosenzweig
Camtek, Ltd. September 17, 2009 Page 2 Form 20-F for the Year Ended December 31, 2006
Item 18. Consolidated Financial Statements
1. We refer to your response to prior comm ent 1. Please also respond with respect
to the Form 20-F for the year ended D ecember 31, 2006. That filing also does not
appear to include audit reports covering each annual period presented. Also, note
that under Exchange Act Rule 12b-15 when you amend a filing the amendment must include the entire text of the amended item(s) and currently dated
certifications.
Form 20-F for the Year Ended December 31, 2008
Note 5 - Inventories, page F-16
2. We note your response to our prior comment 6. In future filings please expand
your disclosures relating to short-term and long-term inventory to address the
substance of your response to our comment.
*****
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Pl ease furnish a cover letter 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 your amendmen t and responses to our comments.
You may contact Jong Hwang at (202) 551-3327 or me at (202) 551-3605 if you
have questions about these comments. In this regard, please do not hesitate to contact
Brian Cascio, Branch Chief, at ( 202) 551-3676 with any other questions.
Sincerely,
Gary Todd Senior Review Accountant