SEC Comment Letter for CAMTEK LTD (CAMT) (CIK 0001109138) (CAMT) — Feb 7, 2011
CAMTEK LTD (CAMT) (CIK 0001109138)
Date: Feb. 7, 2011 · CIK: 0001109138 · Accession: 0000000000-11-007871
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-30664
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE February 7, 2011 Ms. Mira Rosenzweig Chief Financial Officer Camtek Ltd. P.O.Box 544, Ramat Gabr iel Industrial Park Migdal Ha’Emek 23150, Israel Re: Camtek Ltd. Form 20-F for the fiscal year ended December 31, 2009 Filed June 7, 2010 File No. 000-30664
Dear Ms. Rosenzweig: We have reviewed your filing and res ponse dated January 14, 2011 and have the following comments. In some of our comme nts, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstan ces, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments.
Ms. Mira Rosenzweig Camtek Ltd. February 7, 2011 Page 2 Form 20-F for the fiscal year ended December 31, 2009
Item 15T. Controls a nd Procedures, page 77
1. We acknowledge your response to prior comment 6. In future filings please provide enhanced disclosure of the U.S. GAAP and SEC reporting knowledge of the people involved in your financial reporting process. In addition, please disclose your use of, including the nature and extent of involvement, a third party for assistance with your evaluation and assessment of internal controls over financial reporting.
Notes to the Financial Statements, page F-9 Note 1 – General, page F-9
2. We refer to your response to prior comment 9. In future filings, please describe the reasons for material changes in ow nership of Priortech, such as those described in your response. 3. In a related matter, please tell us whet her you have granted any additional options to third parties to purchase Camtek shares. With a view toward future disclosure, please tell us the nature of the transac tion, provide material terms, and describe how you are accounting for the options. Note 2 – Significant Accounting Policies, page F-10
G. Inventories, page F-11
4. We acknowledge your response to our prior comment 15. In future filings, please consider enhancing your l ong-term inventory discussi on by including a disclosure similar to your response beginning “The Company’s policy is to keep components to…” Note 15 – Commitments and Contingencies, page F-27
5. We refer to your response to our prior comm ent 18. In future filings, to the extent you are unable to provide a range of lo ss for each of the litigation matters, consistent with FASB ASC 450, please in dicate that any amount not accrued is not expected to be material to the financ ial statements or the reason that you are unable to provide an estimate.
Ms. Mira Rosenzweig Camtek Ltd. February 7, 2011 Page 3 You may contact Leigh Ann Schultz at 202-551-3628 or me at 202-551-3676 if you have questions regarding comments on the financial statements and related matters. Please contact Louis Rambo at 202-551-3289 or Joseph McCann at 202-551-6262 with any other questions. Sincerely, Brian Cascio Accounting Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
February 7, 2011
Ms. Mira Rosenzweig Chief Financial Officer Camtek Ltd. P.O.Box 544, Ramat Gabr iel Industrial Park
Migdal Ha’Emek 23150, Israel
Re: Camtek Ltd.
Form 20-F for the fiscal year ended December 31, 2009
Filed June 7, 2010 File No. 000-30664
Dear Ms. Rosenzweig:
We have reviewed your filing and res ponse dated January 14, 2011 and have the
following comments. In some of our comme nts, we may ask you to provide us with
information so we may better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstan ces, please tell us why in
your response.
After reviewing the information you provide in response to these comments, we
may have additional comments.
Ms. Mira Rosenzweig
Camtek Ltd. February 7, 2011 Page 2 Form 20-F for the fiscal year ended December 31, 2009
Item 15T. Controls a nd Procedures, page 77
1. We acknowledge your response to prior comment 6. In future filings please provide
enhanced disclosure of the U.S. GAAP and SEC reporting knowledge of the people
involved in your financial reporting process. In addition, please disclose your use of,
including the nature and extent of involvement, a third party for assistance with your
evaluation and assessment of internal controls over financial reporting.
Notes to the Financial Statements, page F-9
Note 1 – General, page F-9
2. We refer to your response to prior comment 9. In future filings, please describe
the reasons for material changes in ow nership of Priortech, such as those
described in your response.
3. In a related matter, please tell us whet her you have granted any additional options
to third parties to purchase Camtek shares. With a view toward future disclosure, please tell us the nature of the transac tion, provide material terms, and describe
how you are accounting for the options.
Note 2 – Significant Accounting Policies, page F-10
G. Inventories, page F-11
4. We acknowledge your response to our prior comment 15. In future filings, please
consider enhancing your l ong-term inventory discussi on by including a disclosure
similar to your response beginning “The Company’s policy is to keep components
to…”
Note 15 – Commitments and Contingencies, page F-27
5. We refer to your response to our prior comm ent 18. In future filings, to the extent
you are unable to provide a range of lo ss for each of the litigation matters,
consistent with FASB ASC 450, please in dicate that any amount not accrued is
not expected to be material to the financ ial statements or the reason that you are
unable to provide an estimate.
Ms. Mira Rosenzweig
Camtek Ltd. February 7, 2011 Page 3
You may contact Leigh Ann Schultz at 202-551-3628 or me at 202-551-3676 if
you have questions regarding comments on the financial statements and related matters.
Please contact Louis Rambo at 202-551-3289 or Joseph McCann at 202-551-6262 with
any other questions.
Sincerely, Brian Cascio Accounting Branch Chief