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SEC Company Response from PDF SOLUTIONS INC (PDFS) (CIK 0001120914) (PDFS) — Dec 14, 2005

PDF SOLUTIONS INC (PDFS) (CIK 0001120914)
Date: Dec. 14, 2005 · CIK: 0001120914 · Accession: 0000950134-05-023150

AI Filing Summary & Sentiment

File numbers found in text: 000-31311

Date
December 14, 2005
Author
Not clearly detected
Form
CORRESP
Company
PDF SOLUTIONS INC (PDFS) (CIK 0001120914)

Letter

United States Securities & Exchange Commission Division of Corporation Finance Form 10-K for Fiscal Year Ended December 31, 2004 Forms 10-Q for Fiscal Quarters Ended March 31, 2005 and June 30, 2005 Form 8-K/A dated July 21, 2005 (File No. 000-31311)

Re:

Dear Ms. Collins:

In connection with its response letter to the United States Securities & Exchange Commission (the “Commission”) regarding the above referenced matter, and as a registrant of the Commission, PDF Solutions, Inc. (the “Company”) affirms the following:

•

The Company is responsible for the adequacy and accuracy of the disclosure in the aforementioned filing;

•

Comments by the Staff of the Commission (the “Staff”) or changes to disclosures in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the aforementioned filing; and

•

The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Company understands the importance of, and is committed to, complying with all applicable SEC rules and regulations. Therefore, should you require additional information or clarification respect to the Company’s responses, or wish to discuss the responses further, please contact me at (408) 938-6445.

Yours truly,

/s/ P. Steven Melman

P. Steven Melman

Vice President, Finance and Administration, and Chief Financial Officer

Show Raw Text
CORRESP
1
filename1.htm

corresp

December 14, 2005

Ms. Kathleen Collins

Accounting Branch Chief

United States Securities & Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    PDF Solutions, Inc.

Form 10-K for Fiscal Year Ended December 31, 2004

Forms 10-Q for Fiscal Quarters Ended March 31, 2005 and June 30, 2005

Form 8-K/A dated July 21, 2005

(File No. 000-31311)

Dear Ms. Collins:

     In connection with its response letter to the United States Securities & Exchange Commission
(the “Commission”) regarding the above referenced matter, and as a registrant of the
Commission, PDF Solutions, Inc. (the “Company”) affirms the following:

    •

    The Company is responsible for the adequacy and accuracy of the disclosure in the
aforementioned filing;

    •

    Comments by the Staff of the Commission (the “Staff”) or changes to
disclosures in response to Staff comments in the filings reviewed by the Staff do not
foreclose the Commission from taking any action with respect to the aforementioned
filing; and

    •

    The Company may not assert Staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

     The Company understands the importance of, and is committed to, complying with all applicable
SEC rules and regulations. Therefore, should you require additional information or clarification
respect to the Company’s responses, or wish to discuss the responses further, please contact me at
(408) 938-6445.

    Yours truly,

    /s/ P. Steven Melman

    P. Steven Melman

    Vice President, Finance and Administration,
and Chief Financial Officer