SEC Comment Letter for BARNWELL INDUSTRIES INC (BRN) (CIK 0000010048) (BRN) — Jan 30, 2012
BARNWELL INDUSTRIES INC (BRN) (CIK 0000010048)
Date: Jan. 30, 2012 · CIK: 0000010048 · Accession: 0000000000-12-005038
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-05103
Letter
January 30, 2012 Via E-mail Russell M. Gifford Chief Financial Officer Barnwell Industries, Inc. 1100 Alakea Street Suite 2900 Honolulu, HI 96813-2833 Re: Barnwell Industries, Inc. Form 10-K for Fiscal Year ended September 30, 2011 Filed December 13, 2011 File No. 001-05103
Dear Mr. Gifford: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10-K
Exhibit 99.1
1. Item 1202(a)(8)(v) of Regulation S-K re quires a discussion of primary economic assumptions utilized in the report. As su ch, please quantify the 12-month average oil price and gas price, as adjusted, used in making the reserves estimation. Closing Comments
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of
Russell M. Gifford Barnwell Industries, Inc. January 30, 2012 Page 2 1934 and all applicable Exchange Act rules requir e. 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 responding to our comments, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of the United States.
Please contact Paul Monsour, Staff Attorne y, at (202) 551-3360, or me at (202) 551-3611 with any questions. Sincerely, /s/ A.N. Parker Anne Nguyen Parker Branch Chief
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January 30, 2012 Via E-mail Russell M. Gifford Chief Financial Officer Barnwell Industries, Inc. 1100 Alakea Street Suite 2900 Honolulu, HI 96813-2833 Re: Barnwell Industries, Inc. Form 10-K for Fiscal Year ended September 30, 2011 Filed December 13, 2011 File No. 001-05103 Dear Mr. Gifford: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10-K Exhibit 99.1 1. Item 1202(a)(8)(v) of Regulation S-K re quires a discussion of primary economic assumptions utilized in the report. As su ch, please quantify the 12-month average oil price and gas price, as adjusted, used in making the reserves estimation. Closing Comments We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of Russell M. Gifford Barnwell Industries, Inc. January 30, 2012 Page 2 1934 and all applicable Exchange Act rules requir e. 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 responding to our comments, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of the United States. Please contact Paul Monsour, Staff Attorne y, at (202) 551-3360, or me at (202) 551-3611 with any questions. Sincerely, /s/ A.N. Parker Anne Nguyen Parker Branch Chief