SEC Office of the Chief Accountant staff letter: Letter from SEC Chief Accountant to Deloitte & Touche LLP, Concerning the Sale by its Member Firms Deloitte Consulting L.P., May 7, 2004

May 12, 2017

May 7, 2004

Deloitte & Touche LLP
Mr. Robert J. Kueppers
Ten Westport Road
Wilton, Connecticut 06897-0820

Dear Mr. Kueppers:

The staff has reviewed your letter on behalf of Deloitte & Touche LLP (D&T) of May 6, 2004 concerning the sale by its member firms Deloitte Consulting L.P., an affiliate of Deloitte & Touche USA LLP (together with D&T, "Deloitte"), of its controlling interest in Telispark, Inc. (Telispark"), a company operating a mobile field service software business, to Infowave Software, Inc. ("Infowave") a public Canadian corporation (together with Telispark "Telispark/Infowave"). For purposes of this letter, Deloitte, includes Deloitte Touche Tohmatsu, a Swiss Verein ("DTT"), DTT member firms, and its and their respective subsidiaries and any other firms conducting audit activities for SEC registrants under the name "Deloitte Touche Tohmatsu," "Deloitte Touche," "Tohmatsu," "Deloitte Consulting" and other combinations or derivations thereof. In your letter, you detail key terms of the transaction and conditions that Deloitte, including entities that have been considered part of Deloitte under Rule 2-01(f)(2) of Regulation S-X, have complied or will comply with in connection with the completion of the transaction. Your letter concludes that, based on its compliance with those terms and conditions, Deloitte should not be considered to have a "mutual or conflicting interest" or a "direct or material indirect business relationship" with, or a "direct financial interest or material indirect financial interest" in, any of its audit clients that are also clients of or enter into business relationships with or invest in Telispark/Infowave, or that are invested in by Telispark/Infowave or its employees.