SEC Comment Letter for LSB INDUSTRIES, INC. (LXU) (CIK 0000060714) (LXU) — Sep 9, 2016
LSB INDUSTRIES, INC. (LXU) (CIK 0000060714)
Date: Sept. 9, 2016 · CIK: 0000060714 · Accession: 0000000000-16-092155
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 8, 2016
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4631 DIVISION OF CORPORATION FINANCE Mail Stop 4631 September 9, 201 6 Via E-Mail Mr. Michael J. Foster Senior Vice President, General Counsel, and Secretary LSB Industries, Inc. 16 South Pennsylvania Avenue Oklahoma City, OK 73107
Re: LSB Industries, Inc. Amendment 1 to Registration Statement on Form S -1 Filed August 26 , 2016 File No. 333 -212503
Dear Mr. Foster:
We have reviewed your amended registration statement 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 by amending your registration statement and providing the requested information . If you do not believe our comments apply t o your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 8, 2016 letter .
General
1. Please request your auditor to revise its consent to clarify that the reports referenced are contained in the company’s F orm 8 -K filed August 26, 2016 and Form 10 -K filed February 29, 2016 .
2. Please also revise your expert s section to refer to the financial statements filed with your Form 8 -K filed August 26, 2016.
Mr. Michael J. Foster LSB Industries, Inc. September 9 , 2016 Page 2 3. Please note that we will not take action to accelerate the effectiveness of the above - captioned registration statement until you resolve outstanding comments on your Form 10 -K for the fis cal year ended December 31, 2015 . The staff’ s comments on your Form 10 -K were issued under separate cover via letter dated September 8, 2016 .
You may contact Edward M. Kelly, Senior Counsel, at (202) 551 -3728 or Asia Timmons -Pierce, Staff Attorney, at (202) 551 -3754 w ith any questions.
Very truly yours ,
Asia Timmons -Pierce, for
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4631
DIVISION OF
CORPORATION FINANCE
Mail Stop 4631
September 9, 201 6
Via E-Mail
Mr. Michael J. Foster
Senior Vice President, General Counsel, and Secretary
LSB Industries, Inc.
16 South Pennsylvania Avenue
Oklahoma City, OK 73107
Re: LSB Industries, Inc.
Amendment 1 to Registration Statement on Form S -1
Filed August 26 , 2016
File No. 333 -212503
Dear Mr. Foster:
We have reviewed your amended registration statement 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 by amending your registration statement and
providing the requested information . If you do not believe our comments apply t o your
facts and circumstances or do not believe an amendment is appropriate, please tell us why
in your response.
After reviewing any amendment to your registration statement and the
information you provide in response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments
in our August 8, 2016 letter .
General
1. Please request your auditor to revise its consent to clarify that the reports referenced
are contained in the company’s F orm 8 -K filed August 26, 2016 and Form 10 -K filed
February 29, 2016 .
2. Please also revise your expert s section to refer to the financial statements filed with
your Form 8 -K filed August 26, 2016.
Mr. Michael J. Foster
LSB Industries, Inc.
September 9 , 2016
Page 2
3. Please note that we will not take action to accelerate the effectiveness of the above -
captioned registration statement until you resolve outstanding comments on your
Form 10 -K for the fis cal year ended December 31, 2015 . The staff’ s comments on
your Form 10 -K were issued under separate cover via letter dated September 8, 2016 .
You may contact Edward M. Kelly, Senior Counsel, at (202) 551 -3728 or Asia
Timmons -Pierce, Staff Attorney, at (202) 551 -3754 w ith any questions.
Very truly yours ,
Asia Timmons -Pierce, for
Pamela A. Long
Assistant Director
Office of Manufacturing and Construction
cc: Via E-Mail
Robert L. Kimball , Esq.
Vinson & Elkins L.L.P.
2001 Ross Avenue, Suite 3700
Dallas, TX 75201 -2975