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SEC Comment Letter for ANTEON INTERNATIONAL CORP (CIK 0001163842) — Aug 31, 2005

ANTEON INTERNATIONAL CORP (CIK 0001163842)
Date: Aug. 31, 2005 · CIK: 0001163842 · Accession: 0000000000-05-045146

AI Filing Summary & Sentiment

File numbers found in text: 001-31258

Referenced dates: August 18, 2005

Date
August 30, 2005
Author
Stephen Krikorian
Form
UPLOAD
Company
ANTEON INTERNATIONAL CORP (CIK 0001163842)

Letter

Room 4561 August 30, 2005 Charles S. Ream Executive Vice President and Chief Financial Officer Anteon International Corporation 3211 Jermantown Road Fairfax, Virginia 22030-2801 (703) 246-0200

Re: Anteon International Corporation Form 10-K for the fiscal year ended December 31, 2004 Filed March 10, 2005 File No. 001-31258

Dear Mr. Ream:

We have reviewed your response letter dated August 18, 2005 and have the following comment. Please note that we have limited our review to the matters addressed in the comment 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K filed March 10, 2005

Notes to Consolidated Financial Statements

Note (2) Summary of Significant Accounting Policies

(h) Revenue Recognition, page F-9

1. We note your response to prior comment number 2. Tell us whether any of your arrangements include multiple units of accounting under EITF 00-21 that involve the development of technology accounted for under the guidance of SOP 81-1 that you subsequently provide operational support for. And, as previously requested, please indicate whether any fees are contingent on the delivery of additional items or meeting other specified performance conditions, such as the performance of operational support. Your response should address how you considered the guidance in paragraph 14 of EITF 00- 21.

* * * * *

As appropriate, please amend your filing and respond to the comment within ten 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 response to our comment.

If you have any questions, please call Morgan Youngwood at (202) 551-3479, Melissa Walsh at (202) 551-3224 or Stephen Krikorian at (202) 551-3730.

Sincerely,
Stephen Krikorian
Accounting Branch Chief

Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Room 4561
      August 30, 2005

Charles S. Ream
Executive Vice President and Chief Financial Officer
Anteon International Corporation
3211 Jermantown Road
Fairfax, Virginia 22030-2801
(703) 246-0200

Re: 	Anteon International Corporation
      Form 10-K for the fiscal year ended December 31, 2004
      Filed March 10, 2005
      File No. 001-31258

Dear Mr. Ream:

      We have reviewed your response letter dated August 18, 2005
and
have the following comment.  Please note that we have limited our
review to the matters addressed in the comment 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K filed March 10, 2005

Notes to Consolidated Financial Statements

Note (2)  Summary of Significant Accounting Policies

(h) Revenue Recognition, page F-9

1. We note your response to prior comment number 2.  Tell us
whether
any of your arrangements include multiple units of accounting
under
EITF 00-21 that involve the development of technology accounted
for
under the guidance of SOP 81-1 that you subsequently provide
operational support for.  And, as previously requested, please
indicate whether any fees are contingent on the delivery of
additional items or meeting other specified performance
conditions,
such as the performance of operational support.  Your response
should
address how you considered the guidance in paragraph 14 of EITF
00-
21.

*	*	*	*	*

      As appropriate, please amend your filing and respond to the
comment within ten 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 response to our comment.

	If you have any questions, please call Morgan Youngwood at
(202)
551-3479, Melissa Walsh at (202) 551-3224 or Stephen Krikorian at
(202) 551-3730.

							Sincerely,

							Stephen Krikorian
							Accounting Branch Chief

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Charles S. Ream
Anteon International Corporation
August 30, 2005
Page 1

</TEXT>
</DOCUMENT>