Mail Stop 4-06
June 16, 2005
Greg Wilson - Chief Financial Officer
Concurrent Computer Corporation
4375 River Green Parkway
Suite 100
Duluth, GA 30096
Re: Concurrent Computer Corporation
Form 10-K for the Fiscal Year Ended June 30, 2004
Forms 10-Q for Fiscal Quarters Ended September 30, 2004, December
31,
2004 and March 31, 2005
File No. 000-13150
Dear Mr. Wilson:
We have reviewed the above referenced filing and have the
following comments. Please note that we have limited our review
to
the matters addressed in the comments below. 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 comments 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-K for the Fiscal Year Ended June 30, 2004
Revenue Recognition and Related Matters, page 52
1. We note from disclosures within the filing that your customers
include government agencies. Considering this, us how you
considered
paragraphs 32 - 33 of SOP 97-2 in accounting for fiscal funding
clauses, if any, included in your software arrangements. Also
tell us how fiscal funding clauses or other government contract
contingencies impact your revenue recognition for other services
and
products you provide.
2. Your Revenue Recognition policy does not appear to address all
the
revenue streams of your Company which appear to include, but are
not
limited to, long-term contracts involving customization, license
fees, hardware, software maintenance, hardware maintenance, other
software sales and video streams purchased. For example you
disclose
that you recognize revenue pursuant to SOP 97-2 and SOP 98-9 but
it
is not evident from this disclosure whether you recognize revenue
for
hardware, hardware maintenance, video streams "purchased" pursuant
to
these standards. Tell us how you recognize revenue for each of
your
revenue streams, the authoritative literature that applies, how
you
determine the fair value for each element in multiple element
arrangements and whether software is integral to the functionality
of
hardware you sell. In your response specifically address your
consideration of EITF 00-21, FTB 90-1 and EITF 03-5 as they relate
to
your revenue recognition policy for products and services.
3. Your disclosure for multiple elements does not appear to fully
comply with the SAB 104, Topic 13.B Question 1, in regards to
clearly
stating the accounting policy for each unit of accounting as well
as
how units of accounting are determined and valued. Tell us how you
plan to more fully comply with this guidance.
As appropriate, please amend your filing and 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.
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 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.
You may contact Megan Akst, Staff Accountant, at (202) 551-
3407
or Tom Ferraro, Senior Staff Accountant who supervised this
review,
at (202) 551-3225 if you have questions regarding comments on the
financial statements and related matters, or me at (202) 551-3730
with any other questions.
Very truly yours,
Craig Wilson
Senior Assistant Chief Accountant
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Greg Wilson
Concurrent Computer Corporation
June 16, 2005
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