SEC Comment Letter for CLAXSON INTERACTIVE GROUP INC (CIK 0001132340) — Aug 15, 2005
CLAXSON INTERACTIVE GROUP INC (CIK 0001132340)
Date: Aug. 15, 2005 · CIK: 0001132340 · Accession: 0000000000-05-042005
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Mail Stop 0407
August 15, 2005
Mr. Jose Antonio Ituarte
Chief Financial Officer
Claxson Interactive Group Inc.
Avenida Melian 2752
C1430EYH Buenos Aires
Argentina
Re: Claxson Interactive Group Inc.
Form 20-F for Fiscal Year Ended December 31, 2004
Filed July 15,2005
File No. 0-33143
Dear Mr. Ituarte:
We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents. Please address the following comments
in
future filings. If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a future revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may or may not raise additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 20-F for the Fiscal Year Ended December 31, 2004
Selected Financial Data, page 2
1. Provide net (loss) income per common share.
Operating and Financial Review and Prospects, page 24
2. Discuss your net (loss) income per common share.
3. Discuss your segment operating income (loss).
Recent Accounting Pronouncements, page 26
4. Tell us how you evaluated the guidance in SFAS 143 in
determining
whether you have a legal retirement obligation associated with the
operation of your tangible long-lived assets. We note that you
have
leased radio transmission towers throughout Chile. Tell us if any
of
these lease agreements include obligations at the end of the lease
term to restore facilities or remove equipment. Please describe
any
other arrangements or situations you considered in evaluating SFAS
143.
Consolidated Statements of Operations and Comprehensive (Loss)
Income, page F-5
5. Please comply with Rules 5-03(b)(1) and 4-08(k) of Regulation
S-X.
Note 3. Acquisitions and Disposals, page F-18
6. Citing the authoritative literature, tell us how you accounted
for
the put and call agreement with Hicks Muse.
* * * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
letter that keys your responses to our comments and provides any
requested information. Detail letters greatly facilitate our
review.
Please file your response letter via EDGAR. Please understand
that
we may have additional comments after reviewing your responses to
our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.
You may contact Bob Carroll, Staff Accountant, at (202) 551-
3362 or Dean Suehiro, Senior Staff Accountant, at (202) 551-3384
if
you have questions regarding comments on the financial statements
and
related matters. Please contact me at (202) 551-3810 with any
other
questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Jose Antonio Ituarte
Claxson Interactive Group Inc.
August 15, 2005
Page 3
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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