SEC Comment Letter for Dominari Holdings Inc. (DOMH) (CIK 0000012239) (DOMH) — Jun 13, 2005
Dominari Holdings Inc. (DOMH) (CIK 0000012239)
Date: June 13, 2005 · CIK: 0000012239 · Accession: 0000000000-05-029640
AI Filing Summary & Sentiment
Letter
Mail Stop 0510 June 13, 2005 Mr. Richard C. Levin Chief Executive Officer, President and Chief Financial Officer, Spherix Incorporated 12051 Indian Creek Court Beltsville, Maryland 20705
RE: Form 10-K for the fiscal year ended December 31, 2004 Form 10-Q for the period ended March 31, 2005 File No. 0-5576
Dear Mr. Levin:
We have reviewed your response and have the following additional comments. If you disagree with a comment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation.
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 December 31, 2004
Statements of Operations, page 21 1. We have reviewed your response to comment three. Based on your response that you have changed your practice of allocating corporate rent to the divisions, we would anticipate a change in reported segment results rather than a change in classification on your statements of operations. Please tell us why the change in the way you evaluate division results has no effect on your segment reporting. 2. Please tell us how you determine what costs are direct contract and operating costs. Please also tell us why you believe the inclusion of costs that do not directly benefit the operations of either division in the direct costs line item was appropriate in the prior year.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Scott Watkinson at (202) 551-3741 or, in his absence, me, at (202) 551-3769 with any other questions.
Sincerely,
Rufus Decker
Accounting Branch Chief
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 0510
June 13, 2005
Mr. Richard C. Levin
Chief Executive Officer, President
and Chief Financial Officer, Spherix Incorporated
12051 Indian Creek Court
Beltsville, Maryland 20705
RE: Form 10-K for the fiscal year ended December 31, 2004
Form 10-Q for the period ended March 31, 2005
File No. 0-5576
Dear Mr. Levin:
We have reviewed your response and have the following
additional comments. If you disagree with a comment, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary. Please be as detailed as necessary in
your
explanation.
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 December 31, 2004
Statements of Operations, page 21
1. We have reviewed your response to comment three. Based on your
response that you have changed your practice of allocating
corporate
rent to the divisions, we would anticipate a change in reported
segment results rather than a change in classification on your
statements of operations. Please tell us why the change in the
way
you evaluate division results has no effect on your segment
reporting.
2. Please tell us how you determine what costs are direct contract
and operating costs. Please also tell us why you believe the
inclusion of costs that do not directly benefit the operations of
either division in the direct costs line item was appropriate in
the
prior year.
* * * *
Please respond to these comments within 10 business days
or
tell us when you will provide us with a response. Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information. Detailed letters greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your responses to our comments.
You may contact Scott Watkinson at (202) 551-3741 or, in his
absence, me, at (202) 551-3769 with any other questions.
Sincerely,
Rufus Decker
Accounting Branch Chief
??
??
??
??
Mr. Richard C. Levin
Spherix Incorporated
June 13, 2005
Page 1 of 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510
DIVISION OF
CORPORATION FINANCE
</TEXT>
</DOCUMENT>