SEC Comment Letter for LGL GROUP INC (LGL) (CIK 0000061004) (LGL) — Nov 24, 2009
LGL GROUP INC (LGL) (CIK 0000061004)
Date: Nov. 24, 2009 · CIK: 0000061004 · Accession: 0000000000-09-066699
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-00106
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549
DIVISION OF CORPORATION FINANCE
Mail Stop 3030 November 24, 2009
VIA U.S. MAIL and FACSIMILE
Mr. Harold D. Castle Chief Financial Officer The LGL Group, Inc. 2525 Shader Road Orlando, Florida 32804 RE: The LGL Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2008 Filed March 31, 2009 Form 10-Q for the Quarter Ended March 31, 2009 Filed May 20, 2009 File No. 001-00106 Dear Mr. Castle: We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments. 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.
Harold D. Castle The LGL Group, Inc. November 24, 2009 Page 2 Form 10-Q for the period ending March 31, 2009
Management’s Discussion and Analysis, page 13
Results of Operations, page 13
1. We note the Company has undertaken a comprehensive “resizing” of its operations. In this regard, please provide us with the applicab le disclosures as prescribed by FASB ASC 420-10-50-1 (p aragraph 20 of SFAS No. 146) and SAB Topic 5:P:4 or tell us why thes e disclosures are not required.
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your response that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please submit your cover letter on EDGAR. Pleas e understand that we may ha ve additional comments after reviewing your responses to our comments. We urge all persons who are responsible for the accuracy and 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 filings; 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 comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities 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.
Harold D. Castle The LGL Group, Inc. November 24, 2009 Page 3 You may contact Dennis Hult, Staff Account ant, at (202) 551-3618 or me at (202) 551-3212 if you have questions regarding comm ents on the financial statements and related matters. In this regard, do not hesitate to contact Ma rtin James, Senior Assistant Chief Accountant, at (202) 551-3671. S i n c e r e l y , Jeffrey Jaramillo A c c o u n t i n g B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3030
November 24, 2009
VIA U.S. MAIL and FACSIMILE
Mr. Harold D. Castle Chief Financial Officer The LGL Group, Inc. 2525 Shader Road Orlando, Florida 32804 RE: The LGL Group, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2008
Filed March 31, 2009 Form 10-Q for the Quarter Ended March 31, 2009 Filed May 20, 2009
File No. 001-00106
Dear Mr. Castle:
We have reviewed your filing and have the following comments. Where
indicated, we think you should revise your document in future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your
explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may
raise additional comments. 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.
Harold D. Castle
The LGL Group, Inc.
November 24, 2009 Page 2 Form 10-Q for the period ending March 31, 2009
Management’s Discussion and Analysis, page 13
Results of Operations, page 13
1. We note the Company has undertaken a comprehensive “resizing” of its
operations. In this regard, please provide us with the applicab le disclosures as
prescribed by FASB ASC 420-10-50-1 (p aragraph 20 of SFAS No. 146) and SAB
Topic 5:P:4 or tell us why thes e disclosures are not required.
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Please furnish a cover letter with your
response that keys your responses to our comments and provides any requested
information. Detailed cover letters greatly facilitate our review. Please submit your
cover letter on EDGAR. Pleas e understand that we may ha ve additional comments after
reviewing your responses to our comments. We urge all persons who are responsible for the accuracy and 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
filings;
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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities 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.
Harold D. Castle
The LGL Group, Inc. November 24, 2009 Page 3
You may contact Dennis Hult, Staff Account ant, at (202) 551-3618 or me at (202)
551-3212 if you have questions regarding comm ents on the financial statements and
related matters. In this regard, do not hesitate to contact Ma rtin James, Senior Assistant
Chief Accountant, at (202) 551-3671. S i n c e r e l y , Jeffrey Jaramillo A c c o u n t i n g B r a n c h C h i e f