SEC Comment Letter for Spansion Inc. (CIK 0001322705) — Dec 5, 2005
Spansion Inc. (CIK 0001322705)
Date: Dec. 5, 2005 · CIK: 0001322705 · Accession: 0000000000-05-060753
AI Filing Summary & Sentiment
File numbers found in text: 333-124041
Letter
Mail Stop 6010 December 5, 2005 Bertrand F. Cambou Chief Executive Officer Spansion Inc. 915 DeGuigne Drive P.O. Box 3453 Sunnyvale, CA 94088
Re: Spansion Inc. Amendment No. 8 to Registration Statement on Form S-1 Filed December 1, 2005 Registration No. 333-124041
Dear Mr. Cambou:
We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a 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 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.
Pending Purchase of Cerium Laboratories, page 131
1. Please provide the disclosures required by Instruction 5 to Item 404 of Regulation S-K.
* * *
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 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.
We direct your attention to Rules 460 and 461 regarding requesting acceleration of a registration statement. Please allow adequate time after the filing of any amendment for further review before submitting a request for acceleration. Please provide this request at least two business days in advance of the requested effective date.
You may contact Thomas Dyer at (202) 551-3641 or Kaitlan Tillan, Assistant Chief Accountant, at (202) 551-3604 if you have questions regarding comments on the financial statements and related matters. Please contact Tim Buchmiller at (202) 551-3635 or me at (202) 551-3617 with any other questions.
Sincerely,
Russell Mancuso
Branch Chief
Show Raw Text
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<TEXT>
Mail Stop 6010
December 5, 2005
Bertrand F. Cambou
Chief Executive Officer
Spansion Inc.
915 DeGuigne Drive
P.O. Box 3453
Sunnyvale, CA 94088
Re: Spansion Inc.
Amendment No. 8 to Registration Statement on Form S-1
Filed December 1, 2005
Registration No. 333-124041
Dear Mr. Cambou:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a 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 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.
Pending Purchase of Cerium Laboratories, page 131
1. Please provide the disclosures required by Instruction 5 to
Item
404 of Regulation S-K.
* * *
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 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.
We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement. Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration. Please provide this
request at least two business days in advance of the requested
effective date.
You may contact Thomas Dyer at (202) 551-3641 or Kaitlan
Tillan, Assistant Chief Accountant, at (202) 551-3604 if you have
questions regarding comments on the financial statements and
related
matters. Please contact Tim Buchmiller at (202) 551-3635 or me at
(202) 551-3617 with any other questions.
Sincerely,
Russell Mancuso
Branch Chief
cc: Tad J. Freese, Esq.
Robert W. Phillips, Esq.
Michael P. Maher, Esq.
(via facsimile)
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Bertrand F. Cambou
Spansion Inc.
December 5, 2005
Page 2
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