SEC Comment Letter for Lee Pharmaceuticals, Inc. (RONN) (CIK 0000058411) — May 10, 2005
Lee Pharmaceuticals, Inc. (RONN) (CIK 0000058411)
Date: May 10, 2005 · CIK: 0000058411 · Accession: 0000000000-05-022817
AI Filing Summary & Sentiment
Referenced dates: April 21, 2005
Letter
April 29, 2005 via U.S. mail and facsimile Mr. Ronald G. Lee Chief Executive Officer and Chief Financial Officer Lee Pharmaceuticals 1444 Santa Anita Avenue South El Monte, California 91733
RE: Form 10-KSB for the fiscal year ended September 30, 2004 Form 10-QSB for the quarter ended December 31, File No. 1-7335
Dear Mr. Lee:
We have reviewed your response letter dated April 21, and have the following additional comments. If you disagree with our 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-KSB FOR YEAR ENDED SEPTEMBER 30, 2004
Comment applicable to your overall filing 1. Where a comment below requests additional disclosures or other revisions, please show us in your supplemental response what the revisions will look like. These revisions should be included in your future filings.
Financial Statements
Note 4 - Intangible Assets, page 21
2. We have reviewed your response to comment 3. Based on your response that you will begin to amortize product line intangibles over 10 to 15 years that were previously determined to have indefinite lives, please quantify for us the annual impact of this change in accounting in 2004 and 2003. Please tell us why you believe that the revised accounting apparently represents a change in estimate as opposed to a correction of an error that would require restatement of your financial statements. Please refer to APB 20, SFAS 16 and SAB Topic 1:M for guidance.
Note 13 - Commitments and Contingencies, page 25
3. Please supplementally tell us why there has no change in your environmental cleanup liability of $374,000 relating to the Casmalia disposal site since 1999. Please also tell us the basis for your conclusion that the estimated environmental obligation has been reduced to $245,000 from $374,000 and the date that you reached this conclusion. Please also tell us what factors you are considering in determining whether to accept the Environmental Protection Agency`s request for only $113,000 of this amount and the date that you received this request. Please also tell us when you expect to respond to the Environmental Protection Agency`s request.
4. Please supplementally tell us the present status of the environmental liabilities classified as short-term of $366,000 and when you expect to settle these obligations.
FORM 10-QSB FOR PERIOD ENDED DECEMBER 31, 2004
Comment applicable to your interim filing
5. Please address the comments above in your interim filings as well.
* * * *
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 supplemental response letter that keys your responses to our comments and provides any requested supplemental information. Detailed letters greatly facilitate our review. Please file your supplemental response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please direct them to Gus Rodriguez, Staff Accountant, at (202) 824-5524 or, in his absence, Nathan Cheney, Assistant Chief Accountant, at (202) 942-1804 or, to the undersigned, at (202) 942-1774.
Sincerely,
Rufus Decker
Accounting Branch Chief
Show Raw Text
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<TEXT>
Mail Stop 0510
April 29, 2005
via U.S. mail and facsimile
Mr. Ronald G. Lee
Chief Executive Officer and Chief Financial Officer
Lee Pharmaceuticals
1444 Santa Anita Avenue
South El Monte, California 91733
RE: Form 10-KSB for the fiscal year ended September 30, 2004
Form 10-QSB for the quarter ended December 31,
2004
File No. 1-7335
Dear Mr. Lee:
We have reviewed your response letter dated April 21,
2005
and have the following additional comments. If you disagree with
our
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-KSB FOR YEAR ENDED SEPTEMBER 30, 2004
Comment applicable to your overall filing
1. Where a comment below requests additional disclosures or other
revisions, please show us in your supplemental response what the
revisions will look like. These revisions should be included in
your
future filings.
Financial Statements
Note 4 - Intangible Assets, page 21
2. We have reviewed your response to comment 3. Based on your
response that you will begin to amortize product line intangibles
over 10 to 15 years that were previously determined to have
indefinite lives, please quantify for us the annual impact of this
change in accounting in 2004 and 2003. Please tell us why you
believe that the revised accounting apparently represents a change
in
estimate as opposed to a correction of an error that would require
restatement of your financial statements. Please refer to APB
20,
SFAS 16 and SAB Topic 1:M for guidance.
Note 13 - Commitments and Contingencies, page 25
3. Please supplementally tell us why there has no change in your
environmental cleanup liability of $374,000 relating to the
Casmalia
disposal site since 1999. Please also tell us the basis for your
conclusion that the estimated environmental obligation has been
reduced to $245,000 from $374,000 and the date that you reached
this
conclusion. Please also tell us what factors you are considering
in
determining whether to accept the Environmental Protection
Agency`s
request for only $113,000 of this amount and the date that you
received this request. Please also tell us when you expect to
respond to the Environmental Protection Agency`s request.
4. Please supplementally tell us the present status of the
environmental liabilities classified as short-term of $366,000 and
when you expect to settle these obligations.
FORM 10-QSB FOR PERIOD ENDED DECEMBER 31, 2004
Comment applicable to your interim filing
5. Please address the comments above in your interim filings as
well.
* * * *
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 supplemental response letter that keys your responses to
our comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review. Please file your
supplemental response on EDGAR as a correspondence file. Please
understand that we may have additional comments after reviewing
your
responses to our comments.
If you have any questions regarding these comments, please
direct them to Gus Rodriguez, Staff Accountant, at (202) 824-5524
or,
in his absence, Nathan Cheney, Assistant Chief Accountant, at
(202)
942-1804 or, to the undersigned, at (202) 942-1774.
Sincerely,
Rufus Decker
Accounting Branch Chief
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Mr. Ronald G. Lee
April 29, 2005
Page 3 of 3
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510
DIVISION OF
CORPORATION FINANCE
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