SEC Comment Letter for COMMVAULT SYSTEMS INC (CVLT) (CIK 0001169561) (CVLT) — Sep 1, 2006
COMMVAULT SYSTEMS INC (CVLT) (CIK 0001169561)
Date: Sept. 1, 2006 · CIK: 0001169561 · Accession: 0000000000-06-042423
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-132550
Referenced dates: August 7, 2006, July 19, 2006
Letter
Room 4561 August 18, 2006 Mr. N. Robert Hammer Chairman of the Board, President and Chief Executive Officer CommVault Systems, Inc. 2 Crescent Place Oceanport, New Jersey 07757
Re: CommVault Systems, Inc. Amendment No. 3 to Registration Statement on Form S-1 filed August 7, 2006 File No. 333-132550
Dear Mr. Hammer:
We have reviewed your amended filing and response letter dated August 7, 2006 and have the following comments.
Amendment No. 3 to Registration Statement on Form S-1
1. We note your response to comment 3 of our letter dated July 19, 2006. Where appropriate, please provide specific disclosure regarding Mr. Hammer’s nonresident status at the location of your offices and include the assessment set forth in your response as to the impact of such a situation on his ability to manage CommVault. Please quantify the amount of time that Mr. Hammer has physically spent in your offices and discuss the basis for reimbursing Mr. Hammer on his commuting and housing expenses.
* * * *
As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
Mr. N. Robert Hammer CommVault Systems, Inc. August 18, 2006 Page 2 You may contact Kari Jin at (202) 551-3481 or Kathy Collins at (202) 551-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Daniel Lee at (202) 551-3477 or me at (202) 551-3462 with any other questions. If you need further assistance, you may contact Barbara Jacobs, Assistant Director, at (202) 551-3730.
Sincerely,
Mark P. Shuman
Branch Chief – Legal
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Room 4561 August 18, 2006 Mr. N. Robert Hammer Chairman of the Board, President and Chief Executive Officer CommVault Systems, Inc. 2 Crescent Place Oceanport, New Jersey 07757 Re: CommVault Systems, Inc. Amendment No. 3 to Registration Statement on Form S-1 filed August 7, 2006 File No. 333-132550 Dear Mr. Hammer: We have reviewed your amended filing and response letter dated August 7, 2006 and have the following comments. Amendment No. 3 to Registration Statement on Form S-1 1. We note your response to comment 3 of our letter dated July 19, 2006. Where appropriate, please provide specific disclosure regarding Mr. Hammer’s nonresident status at the location of your offices and include the assessment set forth in your response as to the impact of such a situation on his ability to manage CommVault. Please quantify the amount of time that Mr. Hammer has physically spent in your offices and discuss the basis for reimbursing Mr. Hammer on his commuting and housing expenses. * * * * As appropriate, please amend your registration statement in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. Mr. N. Robert Hammer CommVault Systems, Inc. August 18, 2006 Page 2 You may contact Kari Jin at (202) 551-3481 or Kathy Collins at (202) 551-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Daniel Lee at (202) 551-3477 or me at (202) 551-3462 with any other questions. If you need further assistance, you may contact Barbara Jacobs, Assistant Director, at (202) 551-3730. Sincerely, Mark P. Shuman Branch Chief – Legal cc: Via Facsimile Philip J. Niehoff, Esq. John R. Sagan, Esq. Mayer, Brown, Rowe & Maw LLP 71 South Wacker Drive Chicago, Illinois 60606 Telephone: (312) 782-0600 Facsimile: (312) 701-7711