SEC Comment Letter for Turtle Beach Corp (TBCH) (CIK 0001493761) (TBCH) — Aug 5, 2010
Turtle Beach Corp (TBCH) (CIK 0001493761)
Date: Aug. 5, 2010 · CIK: 0001493761 · Accession: 0000000000-10-044592
AI Filing Summary & Sentiment
File numbers found in text: 000-54020
Referenced dates: July 21, 2010
Letter
August 5, 2010 Elwood G. Norris Chief Executive Officer Parametric Sound Corporation 1941 Ramrod Avenue, Suite #100 Henderson, Nevada 89014 Re: Parametric Sound Corporation Form 10-12G/A Filed July 27, 2010 File No. 000-54020 Dear Mr. Norris: We have reviewed your amended Form 10 a nd have the following comments. In our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Operating Statements, page 33
1. We note your response to comment 13 from our letter dated July 21, 2010. You state that “the HSS business is properly classified as held and used until the spin-off. At that time, LRAD Corporation will evaluate its accounting under 205-20-45-1 and 45- 5.” Since you are presenting pro forma financial statements giving effect to the spin-off, tell us in detail the factors you cons idered in concluding that the HSS business including the H450 product is not considered discon tinued operations.
Mr. Elwood G. Norris Parametric Sound Corporation August 5, 2010 Page 2 Pro Forma Balance Sheet, page 30
2. We note your response to comment 25 in our letter dated July 21, 2010. Please tell us in detail the factors you consid ered in concluding that the patents and trademarks associated with the H450 product are not impaired.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company and its management are in possession of all facts relating to a co mpany’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
You may contact Kathryn Jacobson at 202-551-3365 or Dean Suehiro at 202-551- 3384 if you have questions regarding comments on the financial statements and related matters. Please contact Jonathan Groff at 202-551-3458 or me at 202-551-3810 with any other questions.
Sincerely,
/s/ Paul Fischer for
Larry Spirgel
A s s i s t a n t D i r e c t o r cc: Via facsimile to (435) 628-1610
Joshua E. Little, Esq.
Show Raw Text
August 5, 2010
Elwood G. Norris Chief Executive Officer
Parametric Sound Corporation
1941 Ramrod Avenue, Suite #100 Henderson, Nevada 89014
Re: Parametric Sound Corporation Form 10-12G/A
Filed July 27, 2010 File No. 000-54020
Dear Mr. Norris:
We have reviewed your amended Form 10 a nd have the following comments. In our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your
response.
After reviewing the information you provide in response to these comments, we may
have additional comments. Operating Statements, page 33
1. We note your response to comment 13 from our letter dated July 21, 2010. You state that “the HSS business is properly classified as held and used until the spin-off. At
that time, LRAD Corporation will evaluate its accounting under 205-20-45-1 and 45-
5.” Since you are presenting pro forma financial statements giving effect to the spin-off, tell us in detail the factors you cons idered in concluding that the HSS business
including the H450 product is not considered discon tinued operations.
Mr. Elwood G. Norris
Parametric Sound Corporation August 5, 2010 Page 2 Pro Forma Balance Sheet, page 30
2. We note your response to comment 25 in our letter dated July 21, 2010. Please tell us
in detail the factors you consid ered in concluding that the patents and trademarks
associated with the H450 product are not impaired.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company and
its management are in possession of all facts relating to a co mpany’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
You may contact Kathryn Jacobson at 202-551-3365 or Dean Suehiro at 202-551-
3384 if you have questions regarding comments on the financial statements and related
matters. Please contact Jonathan Groff at 202-551-3458 or me at 202-551-3810 with any
other questions.
Sincerely,
/s/ Paul Fischer for
Larry Spirgel
A s s i s t a n t D i r e c t o r cc: Via facsimile to (435) 628-1610
Joshua E. Little, Esq.