SEC Comment Letter for @ROAD, INC (CIK 0001109537) — Sep 8, 2005
@ROAD, INC (CIK 0001109537)
Date: Sept. 8, 2005 · CIK: 0001109537 · Accession: 0000000000-05-046417
AI Filing Summary & Sentiment
File numbers found in text: 333-124518
Referenced dates: June 1, 2005
Letter
Room 4561 Krish Panu Chief Executive Officer @Road, Inc. 47071 Bayside Parkway Fremont, California 94538 Form 10-K for the fiscal year ended December 31, 2005 Form 10-Q/A for the quarter ended March 31, 2005 Form 10-Q for the quarter ended March 31, 2005 File No. 0-31511
Re: @Road, Inc. Registration Statement on Form S-3/A Filed August 18, 2005 File No. 333-124518
Dear Mr. Panu:
We limited our review of your filings to disclosure responding to Items 307 and 308(c) of Regulation S-K. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-Q/A for quarter ended March 31, 2005 Controls and Procedures, page 3 1. We refer you to comment 5 of our letter dated June 1, 2005. Please expand your disclosure concerning your disclosure controls and procedures to discuss the specific factors that influenced the determination that despite your identified material weakness in internal controls over financial reporting, your disclosure controls and procedures were effective as of March 31, 2005.
Exhibits 2. We note you have not filed exhibits pursuant to Item 601(b)(32) of Regulation S-K with your amended Form 10-Q. Please revise.
If you have any questions, please call Adam Halper, at (202) 551-3482. If you require additional assistance you may contact me, at (202) 551-3462 or in my absence Barbara C. Jacobs, Assistant Director at, (202) 551-3730.
Sincerely,
Mark P. Shuman
Branch Chief - Legal
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
September 8, 2005
Room 4561
Krish Panu
Chief Executive Officer
@Road, Inc.
47071 Bayside Parkway
Fremont, California 94538
Re: @Road, Inc.
Registration Statement on Form S-3/A
Filed August 18, 2005
File No. 333-124518
Form 10-K for the fiscal year ended December 31, 2005
Form 10-Q/A for the quarter ended March 31, 2005
Form 10-Q for the quarter ended March 31, 2005
File No. 0-31511
Dear Mr. Panu:
We limited our review of your filings to disclosure
responding
to Items 307 and 308(c) of Regulation S-K. If you disagree, we
will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary. Feel free to call us at the telephone
numbers listed at the end of this letter.
Form 10-Q/A for quarter ended March 31, 2005
Controls and Procedures, page 3
1. We refer you to comment 5 of our letter dated June 1, 2005.
Please expand your disclosure concerning your disclosure controls
and
procedures to discuss the specific factors that influenced the
determination that despite your identified material weakness in
internal controls over financial reporting, your disclosure
controls
and procedures were effective as of March 31, 2005.
Exhibits
2. We note you have not filed exhibits pursuant to Item 601(b)(32)
of
Regulation S-K with your amended Form 10-Q. Please revise.
If you have any questions, please call Adam Halper, at (202)
551-3482. If you require additional assistance you may contact
me,
at (202) 551-3462 or in my absence Barbara C. Jacobs, Assistant
Director at, (202) 551-3730.
Sincerely,
Mark P. Shuman
Branch Chief - Legal
cc: Via Facsimile
Kristen Kercher
Heller Ehrman LLP
Fax: (650) 324-6062
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Mr. Krish Panu
@Road, Inc.
September 8, 2005
Page 2
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