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SEC Comment Letter for BARNWELL INDUSTRIES INC (BRN) (CIK 0000010048) (BRN) — Feb 10, 2012

BARNWELL INDUSTRIES INC (BRN) (CIK 0000010048)
Date: Feb. 10, 2012 · CIK: 0000010048 · Accession: 0000000000-12-007561

Financial Reporting Regulatory Compliance Internal Controls

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Confidence
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Reasoning

File numbers found in text: 001-05103

Date
February 10, 2012
Author
A.N. Parker for
Form
UPLOAD
Company
BARNWELL INDUSTRIES INC (BRN) (CIK 0000010048)

Letter

February 10, 2012 Via E-mail Russell M. Gifford Chief Financial OfficerBarnwell Industries, Inc. 1100 Alakea Street Suite 2900 Honolulu, HI 96813-2833 Re: Form 10-K for Fiscal Ye ar ended September 30, 2011 Filed December 13, 2011 File No. 001-05103

Dear Mr. Gifford: We have completed our review of your f iling. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or th e filing and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely,

A.N. Parker for

H. Roger Schwall Assistant Director

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February 10, 2012
 Via E-mail

Russell M. Gifford  Chief Financial OfficerBarnwell Industries, Inc. 1100 Alakea Street Suite 2900 Honolulu, HI 96813-2833
Re: Form 10-K for Fiscal Ye ar ended September 30, 2011
Filed December 13, 2011 File No. 001-05103

Dear Mr. Gifford:
We have completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.
 Sincerely,

A.N. Parker for

H. Roger Schwall Assistant Director