SEC Comment Letter for MOLECULAR DIAGNOSTICS INC (CIK 0000075439) — Aug 2, 2005
MOLECULAR DIAGNOSTICS INC (CIK 0000075439)
Date: Aug. 2, 2005 · CIK: 0000075439 · Accession: 0000000000-05-039647
AI Filing Summary & Sentiment
File numbers found in text: 000-00935
Referenced dates: July 14, 2004, July 14, 2005, June 16, 2005
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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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Mail Stop 6010
August 2, 2005
Mr. Dennis L. Bergquist
Chief Financial Officer
Molecular Diagnostics, Inc.
414 N. Orleans St., Suite 502
Chicago, IL 60610
Re: Molecular Diagnostics, Inc.
Form 10-KSB for the year ended December 31, 2004
File No. 000-00935
Dear Mr. Bergquist:
We have reviewed your response letter dated July 14, 2005.
We
have limited our review to matters related to the issues raised in
our comments. Where indicated, we think you should revise your
document 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. Please 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 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 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 the year ended December 31, 2004
1. Please file your response letter dated July 14, 2004 on EDGAR,
as
required by Regulation S-T.
Item 6 - Management`s Discussion and Analysis or Plan of
Operation,
page 26
Restructuring Settlements, page 30
2. We have reviewed your response to our prior comment 1 in our
letter dated June 16, 2005. It appears that these settlements
relate
to expenses previously included within operating income, therefore
it
would be appropriate to include the related settlements within
operating income. Note the guidance at SAB 67. Please revise
future
filings to address our concerns or tell us why your current
presentation is appropriate, citing any authoritative literature
upon
which you are relying.
Report of Independent Auditors, page F-2
3. We have reviewed your responses to our prior comments 4 and 5
in
our letter dated June 16, 2005. Since Auditeurs & Conseils
Associes opinion was included in your Form 10KSB that was filed
after
May 24, 2004, this opinion must comply with PCAOB Auditing
Standard
No. 1. Please revise the audit report to comply with PCAOB
Standard
1 or tell us why you believe the audit report complies with
current
authoritative auditing literature.
`````
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.
`You may contact Eric Atallah, Staff Accountant at (202)
551-
3663 or me at (202) 551-3603 regarding comments on the financial
statements and related matters. In this regard, do not hesitate
to
contact Angela Crane, Branch Chief, at (202) 551-3554.
Sincerely,
Jay Webb
Reviewing Accountant
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Mr. Dennis L. Bergquist
Molecular Diagnostics, Inc.
August 2, 2005
Page 2
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