SEC Comment Letter for GAMES INC (CIK 0001162093) — Jun 15, 2005
GAMES INC (CIK 0001162093)
Date: June 15, 2005 · CIK: 0001162093 · Accession: 0000000000-05-030148
AI Filing Summary & Sentiment
File numbers found in text: 000-33345
Letter
June 14, 2005 Fax (513) 721-6035 Mail Stop 0406 Roger W. Ach, II Chief Executive Officer Games, Inc. 425 Walnut Street, Suite 2300 Cincinnati, OH 45202
Re: Games, Inc. Form 10-KSB/A for the Fiscal Year Ended June 30, 2004 Filed December 13, 2004 Form 10-QSB for the Fiscal Quarter Ended March 31, 2005 Filed May 23, 2005 File No. 000-33345
Dear Mr. Ach:
We have reviewed the above referenced filings and have the following comments. Please note that we have limited our review to the matters addressed in the comments below. We may ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. After reviewing this information, we may 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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
Item 1. Financial Statements
Notes to Condensed Consolidated Financial Statements
Note C - Deposit on Games.com Assets, page 8
1. We note that your deposit on Games.com assets includes a Games.com URL intangible asset. Please provide us with your valuation methodology and assumptions used to determine the asset`s initial fair value and for any subsequent impairment evaluations. Please specifically address whether the outcome of the litigation with Atari, Inc. resulted in a reassessment of the asset`s recoverability. We refer you to paragraph 8 of SFAS No. 144. 2. We note your statement that the settlement with Atari, Inc. could have a possible adverse effect on your operations. Tell us how you considered SFAS No. 5 in determining whether an accrued liability related to this contingency is considered necessary.
* * * * *
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. You may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter with any amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing any amendment and your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed 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 filing;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the 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.
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 filing or in response to our comments on your filing.
You may contact David Edgar at (202)-551-3459 or Kathleen Collins at (202) 551-3499, or the undersigned at (202) 551-3730 if you have any questions regarding comments on the financial statements and related matters.
Very truly yours,
Craig D. Wilson
Senior Assistant Chief Accountant
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
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<FILENAME>filename1.txt
<TEXT>
June 14, 2005
Fax (513) 721-6035
Mail Stop 0406
Roger W. Ach, II
Chief Executive Officer
Games, Inc.
425 Walnut Street, Suite 2300
Cincinnati, OH 45202
Re: Games, Inc.
Form 10-KSB/A for the Fiscal Year Ended June 30, 2004
Filed December 13, 2004
Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
Filed May 23, 2005
File No. 000-33345
Dear Mr. Ach:
We have reviewed the above referenced filings and have the
following comments. Please note that we have limited our review
to
the matters addressed in the comments below. We may ask you to
provide us with supplemental information so we may better
understand
your disclosure. Please be as detailed as necessary in your
explanation. After reviewing this information, we may 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10-QSB for the Fiscal Quarter Ended March 31, 2005
Item 1. Financial Statements
Notes to Condensed Consolidated Financial Statements
Note C - Deposit on Games.com Assets, page 8
1. We note that your deposit on Games.com assets includes a
Games.com
URL intangible asset. Please provide us with your valuation
methodology and assumptions used to determine the asset`s initial
fair value and for any subsequent impairment evaluations. Please
specifically address whether the outcome of the litigation with
Atari, Inc. resulted in a reassessment of the asset`s
recoverability.
We refer you to paragraph 8 of SFAS No. 144.
2. We note your statement that the settlement with Atari, Inc.
could
have a possible adverse effect on your operations. Tell us how
you
considered SFAS No. 5 in determining whether an accrued liability
related to this contingency is considered necessary.
* * * * *
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T. You
may wish to provide us with marked copies of any amendment to
expedite our review. Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information. Detailed cover letters greatly facilitate
our
review. Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the 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.
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 filing or in
response to our comments on your filing.
You may contact David Edgar at (202)-551-3459 or Kathleen
Collins at (202) 551-3499, or the undersigned at (202) 551-3730 if
you have any questions regarding comments on the financial
statements
and related matters.
Very truly yours,
Craig D. Wilson
Senior Assistant Chief Accountant
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Roger W. Ach, II
Games, Inc.
June 14, 2005
Page 3
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</DOCUMENT>