SEC Comment Letter for Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640) (MLCO) — May 29, 2008
Melco Resorts & Entertainment LTD (MLCO) (CIK 0001381640)
Date: May 29, 2008 · CIK: 0001381640 · Accession: 0000000000-08-027085
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33178
Referenced dates: May 20, 2008
Letter
May 28, 2008 Mail Stop 4561 By U.S. Mail and facsimile to (852) 2537-3618 Mr. Lawrence Ho, Chief Executive Officer Melco PBL Entertainment (Macau) Limited 36 th Floor, The Centrium 60 Wyndham Street Central Hong Kong RE: Melco PBL Entertainment (Macau) Limited File No. 001-33178 Form 20-F for the year ended December 31, 2007
Dear Mr. Ho: We have reviewed the above referenced filing and have the following comment in addition to the comments included in our letter dated May 20, 2008. We have limited our review to only your financial statements and related disclosu res and will make no further review of your documents. As such, all pe rsons who are responsible for the adequacy and accuracy of the disclosures are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934.
We think you should address this comment in future filings. Please confirm in writing that you will do so and also explai n to us how you intend to comply. 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. After reviewing your explanation, we may or may not raise additional comments.
Please understand that the purpose of our re view 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 comment or on any other aspect of our review. Feel free to call us at the tele phone numbers listed at th e end of th is letter. Form 20-F
Item 8.B. Significant Changes, page 85
1. In future filings, please disclose whether or not any significant change has
Melco PBL Entertainment (Macau) Limited Page 2 of 2 occurred since the date of the annual financial statements , and/or since the date of the date of the most recent interim financ ial statements to the extent they are included in the document.
As appropriate, please respond to our commen ts within 10 business days or tell us when you will provide us with a response. Please submit your letter on EDGAR. Please understand that we may have additional comm ents after reviewing your response to our comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision. Since the company and its management are in possession of all facts re lating 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 filings;
• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
• the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filings or in response to our comments on your filings. You may contact Jorge L. Bonilla at ( 202) 551-3414 or me at (202) 551-3498 if you have any questions regard ing comments on the financia l statements and related matters. Please contact Angela McHale at (202) 551-3402 or T homas Kluck, Branch Chief, at (202) 551-3233 with any other questions. Sincerely, Linda van Doorn Senior Assistant Chief Accountant
Show Raw Text
May 28, 2008 Mail Stop 4561
By U.S. Mail and facsimile to (852) 2537-3618
Mr. Lawrence Ho, Chief Executive Officer Melco PBL Entertainment (Macau) Limited 36
th Floor, The Centrium
60 Wyndham Street Central Hong Kong
RE: Melco PBL Entertainment (Macau) Limited
File No. 001-33178
Form 20-F for the year ended December 31, 2007
Dear Mr. Ho:
We have reviewed the above referenced filing and have the following comment in
addition to the comments included in our letter dated May 20, 2008. We have limited our
review to only your financial statements and related disclosu res and will make no further
review of your documents. As such, all pe rsons who are responsible for the adequacy
and accuracy of the disclosures are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934.
We think you should address this comment in future filings. Please confirm in
writing that you will do so and also explai n to us how you intend to comply. 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. After
reviewing your explanation, we may or may not raise additional comments.
Please understand that the purpose of our re view 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 comment or on any other aspect of
our review. Feel free to call us at the tele phone numbers listed at th e end of th is letter.
Form 20-F
Item 8.B. Significant Changes, page 85
1. In future filings, please disclose whether or not any significant change has
Melco PBL Entertainment (Macau) Limited
Page 2 of 2
occurred since the date of the annual financial statements , and/or since the date of
the date of the most recent interim financ ial statements to the extent they are
included in the document.
As appropriate, please respond to our commen ts within 10 business days or tell us
when you will provide us with a response. Please submit your letter on EDGAR. Please
understand that we may have additional comm ents after reviewing your response to our
comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision. Since the company and its
management are in possession of all facts re lating 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
filings;
• staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.
You may contact Jorge L. Bonilla at ( 202) 551-3414 or me at (202) 551-3498 if
you have any questions regard ing comments on the financia l statements and related
matters. Please contact Angela McHale at (202) 551-3402 or T homas Kluck, Branch
Chief, at (202) 551-3233 with any other questions. Sincerely, Linda van Doorn Senior Assistant Chief Accountant