SEC Comment Letter for CERAGON NETWORKS LTD (CRNT) (CIK 0001119769) (CRNT) — Dec 17, 2016
CERAGON NETWORKS LTD (CRNT) (CIK 0001119769)
Date: Dec. 17, 2016 · CIK: 0001119769 · Accession: 0000000000-16-105327
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-30862
Letter
Mail Stop 3720 December 15, 2016 Mr. Doron Arazi Executive Vice President and Chief Financial Officer Ceragon Networks Ltd. 24 Raoul Wallenberg Street Tel Aviv 69719, Israel
Re: Ceragon Networks Ltd. Form 20-F for Fiscal Year Ended December 31, 201 5 Filed March 23, 2016 File No. 000-30862
Dear Mr. Arazi :
We have reviewed your filing and have the following comment.
Please respond to th is comment within ten business days by amending your filing or by advising us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your re sponse and any amendment you may file in response to th is comment, we may have additional comments.
Item 15(b) Management’s Annual Report on Internal Control over Financial Reporting, page 94
1. Please revise as follows:
a. to identify the COSO framework that you used to conduct an evaluation of the effectiveness of your internal control over financial reporting as of December 31, 2015; and
b. to state your conclusion concerning the effectiveness of your Company’s internal control over financial r eporting. In this regard, we note your qualified conclusion stating that “ the Company’s internal control over financial reporting in Brazil is now effective,” instead of “ the Company’s internal control over financial reporting ” as referenced in your audit or’s report.
Mr. Doron Arazi Ceragon Networks Ltd. December 15, 2016 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Dean Suehiro, Senior Staff Accountant at (202) 551 -3384 if you have questions regarding any comment on the financial statements and related matters. Please contact Gregory Dundas, Attorney -Advisor, at (202) 551 -3436 or me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Carlos Pacho for
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Mail Stop 3720 December 15, 2016 Mr. Doron Arazi Executive Vice President and Chief Financial Officer Ceragon Networks Ltd. 24 Raoul Wallenberg Street Tel Aviv 69719, Israel Re: Ceragon Networks Ltd. Form 20-F for Fiscal Year Ended December 31, 201 5 Filed March 23, 2016 File No. 000-30862 Dear Mr. Arazi : We have reviewed your filing and have the following comment. Please respond to th is comment within ten business days by amending your filing or by advising us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your re sponse and any amendment you may file in response to th is comment, we may have additional comments. Item 15(b) Management’s Annual Report on Internal Control over Financial Reporting, page 94 1. Please revise as follows: a. to identify the COSO framework that you used to conduct an evaluation of the effectiveness of your internal control over financial reporting as of December 31, 2015; and b. to state your conclusion concerning the effectiveness of your Company’s internal control over financial r eporting. In this regard, we note your qualified conclusion stating that “ the Company’s internal control over financial reporting in Brazil is now effective,” instead of “ the Company’s internal control over financial reporting ” as referenced in your audit or’s report. Mr. Doron Arazi Ceragon Networks Ltd. December 15, 2016 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Dean Suehiro, Senior Staff Accountant at (202) 551 -3384 if you have questions regarding any comment on the financial statements and related matters. Please contact Gregory Dundas, Attorney -Advisor, at (202) 551 -3436 or me at (202) 551 -3810 with any other questions. Sincerely, /s/ Carlos Pacho for Larry Spirgel Assistant Director AD Office 11 – Telecommunications