-----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, FMfLkiy7BTxyV4v1O9E02Kbg4D+dSni3K11B/x8mC2Sh4UpnWZ0GcyTWbHP7SZ5q GckNuInOmCztT0O8DNqn8Q== 0000000000-05-035272.txt : 20060901 0000000000-05-035272.hdr.sgml : 20060901 20050711161317 ACCESSION NUMBER: 0000000000-05-035272 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050711 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: REGISTER COM INC CENTRAL INDEX KEY: 0001091284 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-BUSINESS SERVICES, NEC [7389] IRS NUMBER: 113239091 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 575 EIGHTH AVE STREET 2: 11TH FLOOR CITY: NEW YORK STATE: NY ZIP: 10018 BUSINESS PHONE: 2127989100 MAIL ADDRESS: STREET 1: 575 8TH AVE STREET 2: 11TH FL CITY: NEW YORK STATE: NY ZIP: 10018 LETTER 1 filename1.txt Mail Stop 4561 July 11, 2005 Ms. Roni A. Jacobson General Counsel and Secretary Register.Com, Inc. 575 Eighth Avenue, 8th Floor New York, NY 10018 RE: Register.Com, Inc. Form 8-K Filed June 6, 2005 File No. 0-29739 Dear Ms. Jacobson: 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 supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not 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 on any other aspect of our review. Feel free to call me at the telephone number listed at the end of this letter. Form 8-K filed June 6, 2005 1. Provide us with any letter or written communication to and from the former accountants regarding any disagreements or reportable events to management or the Audit Committee. 2. Please provide us with a schedule of your fiscal year end fourth quarter adjustments to close the books, or adjustments recorded in connection with or as a result of the audit. Clearly explain the reason for each adjustment. For each adjustment, show us the impact on pre-tax net loss. Quantify the net effect of all adjustments on pre-tax net income (loss). Also, tell us why none of the adjustments relate to prior period. Explain in detail why you believe the timing of each adjustment is appropriate. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed investment decision. Since the company and its management are in possession of all facts relating 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 filing; * staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and * the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing. Please provide the supplemental information requested above within five business days from the date of this letter. The supplemental information should be filed as correspondence on EDGAR. Any questions regarding the above should be directed to me at (202) 551-3469. Sincerely, Thomas Flinn Staff Accountant Ms. Roni A. Jacobson Register.Com, Inc. July 11, 2005 Page 1 -----END PRIVACY-ENHANCED MESSAGE-----