SEC Comment Letter for Turtle Beach Corp (TBCH) (CIK 0001493761) (TBCH) — Aug 13, 2010
Turtle Beach Corp (TBCH) (CIK 0001493761)
Date: Aug. 13, 2010 · CIK: 0001493761 · Accession: 0000000000-10-046551
AI Filing Summary & Sentiment
File numbers found in text: 000-54020
Referenced dates: August 5, 2010
Letter
August 13, 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 response letter da ted August 6, 2010 and your filing and 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 ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your f acts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments.
General
1. Please update your financial statements through June 30, 2010.
Notes to Unaudited Pro Forma Financial Statements, page 33
2. We note your response to comment one from our letter dated August 5, 2010. Due to your plans not to produce the H450 product and to replace it with a new product line after the spin-off, the historical financia l statements are not indicative of your post spin-off operating results. Please revise your pro forma presentation to include adjustments to eliminate the H450 product reve nues and the related cost of revenues.
Mr. Elwood G. Norris Parametric Sound Corporation August 13, 2010 Page 2 In addition, tell us why the $23,434 inventor y balance remains after the pro forma adjustment.
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, Sta ff Accountant, at 202-551-3365 or Dean Suehiro, Staff Accountant, at 202-551-3384 if you have questions regarding comments on the financial statements and related matters. Plea se contact Jonathan Groff, Staff Attorney, 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 13, 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 response letter da ted August 6, 2010 and your filing and 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 ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your f acts and circumstances or do
not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
General
1. Please update your financial statements through June 30, 2010.
Notes to Unaudited Pro Forma Financial Statements, page 33
2. We note your response to comment one from our letter dated August 5, 2010. Due to
your plans not to produce the H450 product and to replace it with a new product line
after the spin-off, the historical financia l statements are not indicative of your post
spin-off operating results. Please revise your pro forma presentation to include
adjustments to eliminate the H450 product reve nues and the related cost of revenues.
Mr. Elwood G. Norris
Parametric Sound Corporation August 13, 2010 Page 2
In addition, tell us why the $23,434 inventor y balance remains after the pro forma
adjustment.
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, Sta ff Accountant, at 202-551-3365 or Dean
Suehiro, Staff Accountant, at 202-551-3384 if you have questions regarding comments on the
financial statements and related matters. Plea se contact Jonathan Groff, Staff Attorney, 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.