SEC Comment Letter for LGL GROUP INC (LGL) (CIK 0000061004) (LGL) — Apr 17, 2008
LGL GROUP INC (LGL) (CIK 0000061004)
Date: April 17, 2008 · CIK: 0000061004 · Accession: 0000000000-08-019783
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 6010 April 17, 2008 Harold Castle Chief Financial Officer The LGL Group, Inc. 2525 Shader Road Orlando, FL 32804
Re: THE LGL Group, Inc.
Item 4.02 Form 8-K
Filed April 16, 2008
File No. 1-00106
Dear Mr. Castle:
We have reviewed your filing and have the following comments.
1. Please tell us whether you intend to file rest ated financial statements. If so, tell us
how and when you intend to do so. We ma y have further comment after you file
the restated financial statements.
2. Please tell us if your certifying officer s have reconsidered the effect on the
adequacy of your disclosure controls and procedures as of the end of the period
covered by your Forms 10-Q for the period ended March 31, 2007 in light of the material error you have disclosed. Additiona lly, tell us what affect the error had
on your current evaluation of disclosure cont rols and procedures as of your fiscal
year end December 31, 2007.
Harold Castle
The LGL Group, Inc.
April 17, 2008 Page 2
As appropriate, please respond to these co mments within five business days or
tell us when you will provide us with a response. We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
If you have any questions, please call me at (202) 551-3618. In this regard, do
not hesitate to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-3554.
S i n c e r e l y , D e n n i s C . H u l t S t a f f A c c o u n t a n t