-----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, OryWHCYDpnxLTTNRf8DhLqSexb8i3mf+j/JRSKO9xH1WaWPMpR0wmvWHLPj8GTrr fCQFYQKo4XBDaRrs6cpvew== 0000950152-05-008839.txt : 20061004 0000950152-05-008839.hdr.sgml : 20061004 20051107160221 ACCESSION NUMBER: 0000950152-05-008839 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20051107 FILER: COMPANY DATA: COMPANY CONFORMED NAME: REYNOLDS & REYNOLDS CO CENTRAL INDEX KEY: 0000083588 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-COMPUTER INTEGRATED SYSTEMS DESIGN [7373] IRS NUMBER: 310421120 STATE OF INCORPORATION: OH FISCAL YEAR END: 0930 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE REYNOLDS WAY CITY: DAYTON STATE: OH ZIP: 45430 BUSINESS PHONE: 9374852000 MAIL ADDRESS: STREET 1: P.O. BOX 2608 CITY: DAYTON STATE: OH ZIP: 45401 CORRESP 1 filename1.htm Reynolds & Reynolds Correspondence
 

November 7, 2005
Mr. Stephen Krikorian
Accounting Branch Chief
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Re:    The Reynolds and Reynolds Company (File no. 001-10147)
Form 10-K: For the Year Ended September 30, 2004
Form 10-Q: For the Quarterly Period Ended December 31, 2004
Form 10-Q: For the Quarterly Period Ended March 31, 2005
Form 10-Q: For the Quarterly Period Ended June 30, 2005
Dear Mr. Krikorian,
During the telephone discussions on November 4, between Mr. Thomas Ferraro, Senior Staff Accountant, and Mr. John Huber of Latham & Watkins, LLP, counsel to The Reynolds and Reynolds Company (the “Company”), Mr. Huber advised the SEC Staff that the Company had been delayed in providing its response to the Staff on November 4, 2005 because of the following: (i) the Company is gathering additional information and performing additional analysis with respect to its determination regarding vendor-specific objective evidence (VSOE) of fair value for post-contract customer support (PCS); and (ii) determining whether applying an aggregate convention to record revenues from delivery of hardware and software, installation and training would be materially the same as accounting for each transaction individually.
Given these issues, the Company expects that it will be able to provide a white paper describing its revenue recognition policy and any changes to its revenue recognition policy, with a macro level discussion of the estimated effects of any such changes, on November 21, 2005. While the SEC Staff is reviewing the white paper, the Company will quantify the specifics of the ultimate effects of any such changes to the SEC Staff and submit the specific analysis to the SEC Staff.

 

 

Mr. Huber also informed the SEC Staff that the Company expects to have a change with regard to hardware revenue and cost; while this change deals with one-time revenue, rather than all revenue, the amount of such change has not yet been determined. During his conversations with the SEC Staff, Mr. Huber stated that if a determination is made that the Company’s financial statements cannot be relied upon because of a revenue recognition issue or restatement, the Company will timely file a second Current Report on Form 8-K regarding Item 4.02(a) under Form 8-K and promptly disclose the nature of the revenue recognition issue or restatement in a press release. This letter confirms Mr. Huber’s statements to the SEC Staff.
Please be advised that Mr. Huber will call Mr. Ferraro on November 10, 2005 (instead of November 11th which is a federal holiday) and November 18, 2005 to apprise the SEC Staff of the status of these matters.
Sincerely,

/s/ Joyce Murty
Joyce Murty
Senior Corporate Counsel
Mr. Craig Wilson, Senior Assistant Chief Accountant
Mr. Thomas Ferraro, Senior Staff Accountant
Mr. Christopher White, Staff Accountant
Mr. John Huber, Latham & Watkins

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