SEC Company Response from CAMTEK LTD (CAMT) (CIK 0001109138) (CAMT) — Sep 30, 2009
CAMTEK LTD (CAMT) (CIK 0001109138)
Date: Sept. 30, 2009 · CIK: 0001109138 · Accession: 0001178913-09-002301
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-30664
Referenced dates: September 17, 2009
Letter
Forms 20-F for Fiscal Years Ended December 31, 2006, 2007 and 2008 Filed on June 29, 2007, June 30, 2008 and April 8, 2009 File No. 000-30664
RE: Camtek LTD.
Dear Mr. Todd:
In connection with your letter dated September 17, 2009 to Mira Rosenzweig, Chief Financial Officer of Camtek Ltd. (“Camtek” or the “Company”), we are providing the following responses to the comments made by the Securities and Exchange Commission (the “Commission” or the “Staff” ). To assist you in your review, we have included the heading and comments from that letter in italics below followed by the Company’s responses in regular typeface.
Form 20-F for the Year Ended December 31, 2006.
Item 18 Consolidated Financial Statements.
1. We refer to your response to prior comment 1. Please also respond with respect to the Form 20-F for the year ended December 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 the filing the amendment must include the entire text of the amendment item(s and currently dated certifications.
Response:
The consolidated financial statements for the three-year period ended December 31, 2005, had been jointly audited by Goldstein Sabo Tevet and Brightman Almagor & Co., a member firm of Deloitte Touche Tohmatsu, independent registered public accounting firm. Further, the consolidated financial statements for the year ended December 31, 2006, were audited by Somekh Chaikin, a member firm of KPMG International, independent registered public accounting firm.
An auditors report for the year ended December 31, 2006 was filed in the 2006 Form 20-F as part of the financial statements under Item 18. The audit report for the two years ended December 31, 2005 should have been filed under Item 18 to the 2006 Form 20-F filed on June 29, 2007 but were unintentionally omitted. An amended 2006 Form 20-F, Item 18 which will include the omitted audit reports will be filed immediately following completion of the process of responding to the Staff’s comments, together with currently dated certifications.
C a m t e k L t d. n Ramat Gavriel, Ha'arig Street, P.O. Box 544, Migdal-Haemek 23150, Israel
Tel: +972-4-6048100 n Fax: +972-4-6440523
E-Mail: info@camtek.co.il n Web site: http://www.camtek.co.il
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.
Response:
In future filings, the Company will expand the description relating to short-term and long-term inventory in order to address the substance of its accounting rationale as described in its answer to the Staff’s prior comment 6.
Should you have any further questions on the above, please do not hesitate to contact me at +972-4-6048308.
Sincerely,
/s/ Mira Rosenzweig
——————————————
Show Raw Text
CORRESP
1
filename1.htm
Corresp
VIA ELECTRONIC
TRANSMISSION
Mr. Gary Todd
Senior Review Accountant
U.S. Securities and Exchange Commission
Washington, D.C. 20549
RE:
Camtek
LTD.
Forms
20-F for Fiscal Years Ended December 31, 2006, 2007 and 2008
Filed
on June 29, 2007, June 30, 2008 and April 8, 2009
File
No. 000-30664
Dear Mr. Todd:
In
connection with your letter dated September 17, 2009 to Mira Rosenzweig, Chief Financial
Officer of Camtek Ltd. (“Camtek” or the “Company”), we are providing
the following responses to the comments made by the Securities and Exchange Commission
(the “Commission” or the “Staff” ). To assist you in your review, we
have included the heading and comments from that letter in italics below followed by the
Company’s responses in regular typeface.
Form 20-F for the Year Ended
December 31, 2006.
Item 18 Consolidated
Financial Statements.
1.
We
refer to your response to prior comment 1. Please also respond with
respect to the Form 20-F for the year ended December 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 the filing the amendment must include the entire text of the
amendment item(s and currently dated certifications.
Response:
The consolidated financial statements
for the three-year period ended December 31, 2005, had been jointly audited by Goldstein
Sabo Tevet and Brightman Almagor & Co., a member firm of Deloitte Touche Tohmatsu,
independent registered public accounting firm. Further, the consolidated financial
statements for the year ended December 31, 2006, were audited by Somekh Chaikin, a member
firm of KPMG International, independent registered public accounting firm.
An auditors report for the year ended
December 31, 2006 was filed in the 2006 Form 20-F as part of the financial statements
under Item 18. The audit report for the two years ended December 31, 2005 should have been
filed under Item 18 to the 2006 Form 20-F filed on June 29, 2007 but were unintentionally
omitted. An amended 2006 Form 20-F, Item 18 which will include the omitted audit reports
will be filed immediately following completion of the process of responding to the
Staff’s comments, together with currently dated certifications.
C a m t e k L t d. n Ramat Gavriel, Ha'arig Street, P.O. Box 544, Migdal-Haemek 23150, Israel
Tel: +972-4-6048100 n Fax: +972-4-6440523
E-Mail: info@camtek.co.il n Web site: http://www.camtek.co.il
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.
Response:
In
future filings, the Company will expand the description relating to short-term and
long-term inventory in order to address the substance of its accounting rationale as
described in its answer to the Staff’s prior comment 6.
Should
you have any further questions on the above, please do not hesitate to contact me at
+972-4-6048308.
Sincerely,
/s/ Mira Rosenzweig
——————————————
Mira Rosenzweig
Chief Financial Officer.
C a m t e k L t d. n Ramat Gavriel, Ha'arig Street, P.O. Box 544, Migdal-Haemek 23150, Israel
Tel: +972-4-6048100 n Fax: +972-4-6440523
E-Mail: info@camtek.co.il n Web site: http://www.camtek.co.il