SEC Comment Letter for VIATEL HOLDING BERMUDA LTD (CIK 0001175597) — Oct 5, 2005
VIATEL HOLDING BERMUDA LTD (CIK 0001175597)
Date: Oct. 5, 2005 · CIK: 0001175597 · Accession: 0000000000-05-051197
AI Filing Summary & Sentiment
File numbers found in text: 000-50556
Referenced dates: August 11, 2005, September 8, 2005
Letter
October 4, 2005 Via U.S. Mail and Fax (44-17-8449-4281) Mr. Brian McArthur Muscroft Chief Financial Officer Viatel Holding (Bermuda) Limited Inbucon House Wick Road Egham, Surrey TW20 0HR United Kingdom
Re: Viatel Holding (Bermuda) Limited Form 20-F for the Year Ended December 31, 2004 File No. 000-50556
Dear Mr. Muscroft:
We have reviewed your supplemental response letter dated September 8, 2005 as well as your filing and have the following comment. As noted in our comment letter dated August 11, 2005, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
1. We note in your response to comment 2 your expectation of fully recovering your communications systems and network infrastructure assets (the "Network"). Your test for impairment was based upon cash flow projections provided by management to your board of directors and the investors. In light of the successor company`s negative cash flows from operations since 2002, we remain concerned about the ultimate recoverability of your Network assets. Please expand your critical accounting policy disclosure in MD&A to explain to investors, in detail, management`s consideration of a possible impairment in the carrying value of the company`s Network assets. This discussion should be in a sufficient level of detail so that your methodology for estimating fair value, the assumptions made by management when estimating fair value, and the events that must occur in order for those assumptions and estimates to be realized are transparent to investors. You should describe how the cash flow projections provided to your board of directors were developed and what must occur operationally in order for the company to realize these positive cash flows. You should explain to readers why you believe your assumptions about future cash flows are reasonable. Also, discuss the likelihood of materially different reported results if different assumptions or conditions were to prevail. Refer to paragraphs B21 and B22 of FAS 144 for a discussion of methodologies for estimating future cash flows.
* * * *
Please respond to the above comment within 10 business days or tell us when you will provide us with a response. You may contact Andrew Mew, Senior Staff Accountant, at (202) 551-3377 or Robert S. Littlepage, Jr., Accounting Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 if you have any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mail Stop 3561
October 4, 2005
Via U.S. Mail and Fax (44-17-8449-4281)
Mr. Brian McArthur Muscroft
Chief Financial Officer
Viatel Holding (Bermuda) Limited
Inbucon House
Wick Road
Egham, Surrey TW20 0HR
United Kingdom
Re: Viatel Holding (Bermuda) Limited
Form 20-F for the Year Ended December 31, 2004
File No. 000-50556
Dear Mr. Muscroft:
We have reviewed your supplemental response letter dated
September 8, 2005 as well as your filing and have the following
comment. As noted in our comment letter dated August 11, 2005, we
have limited our review to your financial statements and related
disclosures and do not intend to expand our review to other
portions
of your documents.
1. We note in your response to comment 2 your expectation of fully
recovering your communications systems and network infrastructure
assets (the "Network"). Your test for impairment was based upon
cash
flow projections provided by management to your board of directors
and the investors. In light of the successor company`s negative
cash
flows from operations since 2002, we remain concerned about the
ultimate recoverability of your Network assets. Please expand
your
critical accounting policy disclosure in MD&A to explain to
investors, in detail, management`s consideration of a possible
impairment in the carrying value of the company`s Network assets.
This discussion should be in a sufficient level of detail so that
your methodology for estimating fair value, the assumptions made
by
management when estimating fair value, and the events that must
occur
in order for those assumptions and estimates to be realized are
transparent to investors. You should describe how the cash flow
projections provided to your board of directors were developed and
what must occur operationally in order for the company to realize
these positive cash flows. You should explain to readers why you
believe your assumptions about future cash flows are reasonable.
Also, discuss the likelihood of materially different reported
results
if different assumptions or conditions were to prevail. Refer to
paragraphs B21 and B22 of FAS 144 for a discussion of
methodologies
for estimating future cash flows.
* * * *
Please respond to the above comment within 10 business days
or
tell us when you will provide us with a response. You may contact
Andrew Mew, Senior Staff Accountant, at (202) 551-3377 or Robert
S.
Littlepage, Jr., Accounting Branch Chief, at (202) 551-3361 if you
have questions regarding comments on the financial statements and
related matters. Please contact me at (202) 551-3810 if you have
any
other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Brian McArthur Muscroft
Viatel Holding (Bermuda) Limited
October 4, 2005
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