SEC Comment Letter for LSB INDUSTRIES, INC. (LXU) (CIK 0000060714) (LXU) — Feb 4, 2008
LSB INDUSTRIES, INC. (LXU) (CIK 0000060714)
Date: Feb. 4, 2008 · CIK: 0000060714 · Accession: 0000000000-08-006162
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE January 30, 2008 Via U.S. mail and facsimile Mr. Tony M. Shelby Chief Financial Officer LSB Industries, Inc. 16 South Pennsylvania Avenue Oklahoma City, Oklahoma 73107
RE: Form 10-K/A for the fiscal year ended December 31, 2006 Form 10-K for the fiscal year ended December 31, 2006 Form 10-Q for the peri od ended September 30, 2007 File No. 1-7677
Dear Mr. Shelby:
We have reviewed your response lett er dated January 22, 2008 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 nece ssary in your explanation.
Please understand that the purpose of our re view 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 YEAR ENDED DECEMBER 31, 2006
General
1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like. These revisions should be included in your future filings.
Mr. Tony M. Shelby January 30, 2008 Page 2 of 2 Item 9A – Controls a nd Procedures, page 69
2. We note your response to prior comment 9. Pl ease expand your disclosure to address the nature of the sign ificant deficiencies th at you noted during your evaluation as well as how you were able to conc lude that your disclosure c ontrols and procedures were effective in light of these deficiencies.
FORM 10-Q FOR THE PERIOD ENDED SEPTEMBER 30, 2007
General
3. Please address the above comment in your interim filings as well.
* * * *
Please respond to these comments with in 10 business days, or tell us when you will provide us with a response. Please pr ovide us with a supplemental response letter that keys your responses to our comment s 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 reviewin g your responses to our comments.
If you have any questions regarding these comments, please direct them to Nudrat Salik, Staff Accountant, at ( 202) 551-3692 or, in her absence, to the undersigned at (202) 551-3769.
S i n c e r e l y ,
R u f u s D e c k e r Accounting Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
January 30, 2008
Via U.S. mail and facsimile
Mr. Tony M. Shelby
Chief Financial Officer
LSB Industries, Inc.
16 South Pennsylvania Avenue
Oklahoma City, Oklahoma 73107
RE: Form 10-K/A for the fiscal year ended December 31, 2006
Form 10-K for the fiscal year ended December 31, 2006
Form 10-Q for the peri od ended September 30, 2007
File No. 1-7677
Dear Mr. Shelby:
We have reviewed your response lett er dated January 22, 2008 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 nece ssary in your explanation.
Please understand that the purpose of our re view 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 YEAR ENDED DECEMBER 31, 2006
General
1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like. These revisions should be included in your future filings.
Mr. Tony M. Shelby
January 30, 2008
Page 2 of 2
Item 9A – Controls a nd Procedures, page 69
2. We note your response to prior comment 9. Pl ease expand your disclosure to address
the nature of the sign ificant deficiencies th at you noted during your evaluation as well
as how you were able to conc lude that your disclosure c ontrols and procedures were
effective in light of these deficiencies.
FORM 10-Q FOR THE PERIOD ENDED SEPTEMBER 30, 2007
General
3. Please address the above comment in your interim filings as well.
* * * *
Please respond to these comments with in 10 business days, or tell us when you
will provide us with a response. Please pr ovide us with a supplemental response letter
that keys your responses to our comment s 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 reviewin g your responses to our comments.
If you have any questions regarding these comments, please direct them to Nudrat
Salik, Staff Accountant, at ( 202) 551-3692 or, in her absence, to the undersigned at (202)
551-3769.
S i n c e r e l y ,
R u f u s D e c k e r
Accounting Branch Chief