-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, JIlAOyYjSEoNI64fu6K/gjBZbD+jakTEMSbS4+1WXPKBxGVWWOofZhtA7GPFURlB RsQ3TNp9MFlo1M8F5QXMGw== 0000000000-05-046961.txt : 20060908 0000000000-05-046961.hdr.sgml : 20060908 20050912134558 ACCESSION NUMBER: 0000000000-05-046961 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050912 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: CNET NETWORKS INC CENTRAL INDEX KEY: 0001015577 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-BUSINESS SERVICES, NEC [7389] IRS NUMBER: 133696170 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 235 SECOND STREET CITY: SAN FRANCISCO STATE: CA ZIP: 94105 BUSINESS PHONE: 4153442000 MAIL ADDRESS: STREET 1: 235 SECOND STREET CITY: SAN FRANCISCO STATE: CA ZIP: 94105 FORMER COMPANY: FORMER CONFORMED NAME: CNET INC /DE DATE OF NAME CHANGE: 19970506 PUBLIC REFERENCE ACCESSION NUMBER: 0001193125-05-052842 LETTER 1 filename1.txt Mail Stop 4561 September 12, 2005 VIA USMAIL and FAX (415) 344-1234 Mr. George Mazzotta Executive Vice President and Chief Financial Officer CNET Networks, Inc. 235 Second Street San Francisco, CA 94105 Re: CNET Networks, Inc. Form 10-K for the year ended 12/31/2004 Filed 3/16/2005 File No. 000-20939 Dear Mr. George Mazzotta: We have reviewed your response letter dated September 1, 2005 and have the following additional comment. Where indicated, we think you should revise your document[s] in response to this comment in future filings. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. FORM 10-K FOR THE YEAR ENDED MARCH 31, 2005 Item 7. Management`s Discussion and Analysis of Financial Condition and Results of Operation 2004 Results, pages 13 - 14 1. We have read your response to comment 1. Since you use this measure as a performance measure, the justification for excluding items because they do not affect cash flows or vary by period is not persuasive. You have recognized asset impairment in 2004 and 2002 and the nature of asset impairments is such that it is reasonably likely to recur. We believe the facts and circumstances do not support the adjustment of asset impairment charges in accordance to Item 10 (e) of Regulation S-K. In future filings, please revise to exclude your adjustment for asset impairment charges. * * * * As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your proposed revisions that keys your response to our comment. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment. You may contact Wilson K. Lee, at (202) 551-3468 or me, at (202) 551-3498 if you have questions. Sincerely, Linda Van Doorn Senior Assistant Chief Accountant ?? ?? ?? ?? George Mazzotta CNET Networks, Inc. September 12, 2005 Page 1 -----END PRIVACY-ENHANCED MESSAGE-----