-----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, OVpmJ4QxLmpRUn5h0jzsMvLB6VC7VTAJUMy1+0+aH29z/sqQavDyXWvxkylK+J79 vop/5R5A7F/2jMsFcXzu9w== 0000000000-05-038683.txt : 20060628 0000000000-05-038683.hdr.sgml : 20060628 20050727154450 ACCESSION NUMBER: 0000000000-05-038683 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050727 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: DIGITAL FUSION INC/NJ/ CENTRAL INDEX KEY: 0001057257 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-COMPUTER PROGRAMMING, DATA PROCESSING, ETC. [7370] IRS NUMBER: 133817344 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 5030 BRADFORD DRIVE NW STREET 2: SUITE 210 CITY: HUNTSVILLE STATE: AL ZIP: 35805 BUSINESS PHONE: 2568372620 MAIL ADDRESS: STREET 1: 5030 BRADFORD DRIVE NW STREET 2: SUITE 210 CITY: HUNTSVILLE STATE: AL ZIP: 35805 FORMER COMPANY: FORMER CONFORMED NAME: IBS INTERACTIVE INC DATE OF NAME CHANGE: 19980306 PUBLIC REFERENCE ACCESSION NUMBER: 0001157523-05-002967 LETTER 1 filename1.txt Room 4561 July 27, 2005 Mr. Roy E. Crippen III Chief Executive Officer and Chairman of the Board Digital Fusion, Inc. 4940-A Corporate Drive Huntsville, AL 35805 Re: Digital Fusion, Inc. Form 10-KSB for Fiscal Year Ended December 31, 2004 Form 10-QSB for Fiscal Quarter Ended March 31, 2005 File No. 0-24073 Dear Mr. Crippen, We have reviewed your response letter dated July 26, 2005 and have the following additional comments. We may ask you to provide us with supplemental information so we may better understand your disclosure. Please be as detailed as necessary in your explanation. After reviewing this information, we may 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 comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-KSB For Fiscal Year Ended December 31, 2004 Note 2. Significant Accounting Policies (b) Revenue Recognition, page F-7 1. We have read your response to prior comment number 3 and note that you assume we are referring to "fixed price" contracts for which you are recognizing revenue using the proportional performance method rather than "fixed fee" contracts accounted for using the percentage of completion method. Please note that we are referring to your contracts that are on a "fixed fee basis" and accounted for "on a percentage of completion basis" as disclosed in your revenue recognition policy on page F-7 of your 2004 Form 10-KSB. Please clarify for us whether you have any contracts that are on a "fixed fee basis" and accounted for "on a percentage of completion basis." If so, explain to us why you account for these contracts using the percentage of completion method. Note 6. Borrowings, page F-12 2. We have read your response to prior comment 4 and note that you considered the debt modifications to be troubled debt restructurings subject to the guidance in SFAS 15. Please explain to us how you determined that the modifications represented concessions granted by your creditors in accordance with paragraph 11 of EITF 02-04. As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. You may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter with any amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing any amendment and your responses to our comments. You may contact Mark Kronforst at (202) 551-3451, Marc D. Thomas at (202) 551-3452 or me at (202) 551-3489 if you have any questions regarding these comments. Very truly yours, Brad Skinner Accounting Branch Chief ?? ?? ?? ?? Roy E. Crippen III Digital Fusion, Inc. July 27, 2005 Page 2 -----END PRIVACY-ENHANCED MESSAGE-----