SEC Comment Letter for PARK AEROSPACE CORP (PKE) (CIK 0000076267) (PKE) — May 8, 2012
PARK AEROSPACE CORP (PKE) (CIK 0000076267)
Date: May 8, 2012 · CIK: 0000076267 · Accession: 0000000000-12-023915
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 6, 2012, March 9, 2012
Letter
May 8, 2012 Via Facsimile Brian E. Shore President and Chief Executive Officer Park Electrochemical Corp. 48 South Service Road Melville, NY 11747
Re: Park Electrochemical Corp. Form 10-K for the Fiscal Year Ended February 27, 2011 Filed on May 12, 2011 Forms 8 -K filed on September 27, 2011, December 21, 2011 and May 1, 2012 File No. 001 -04415
Dear Mr. Shore :
We have reviewed you r letter dated April 6, 2012 in connection with the abo ve- referenced filing s and have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your respon se.
After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments . Unless otherwise noted, where prior comments are referred to they refer to our letter dated March 9, 2012 .
Form 8 -K filed on May 1, 2012 1. Notwithstanding the first paragraph of your response to prior comment 8, we continue to believe that the non -GAAP operating statement format appearing on page 9 conveys undue prominence to a statement based on non -GAAP inform ation and should be removed. Please exclude this presentation from future filings.
Brian E. Shore Park Electrochemical Corp. May 8, 2012 Page 2
You may contact Tamara J. Tangen, Staff Accountan t, at (202) 551 -3443 if you have questions regarding comments on the financial statements and re lated matters. Please co ntact me at (202) 551 -3730 with any other questions.
Sincerely,
/s/ Craig D. Wilson
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May 8, 2012 Via Facsimile Brian E. Shore President and Chief Executive Officer Park Electrochemical Corp. 48 South Service Road Melville, NY 11747 Re: Park Electrochemical Corp. Form 10-K for the Fiscal Year Ended February 27, 2011 Filed on May 12, 2011 Forms 8 -K filed on September 27, 2011, December 21, 2011 and May 1, 2012 File No. 001 -04415 Dear Mr. Shore : We have reviewed you r letter dated April 6, 2012 in connection with the abo ve- referenced filing s and have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your respon se. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments . Unless otherwise noted, where prior comments are referred to they refer to our letter dated March 9, 2012 . Form 8 -K filed on May 1, 2012 1. Notwithstanding the first paragraph of your response to prior comment 8, we continue to believe that the non -GAAP operating statement format appearing on page 9 conveys undue prominence to a statement based on non -GAAP inform ation and should be removed. Please exclude this presentation from future filings. Brian E. Shore Park Electrochemical Corp. May 8, 2012 Page 2 You may contact Tamara J. Tangen, Staff Accountan t, at (202) 551 -3443 if you have questions regarding comments on the financial statements and re lated matters. Please co ntact me at (202) 551 -3730 with any other questions. Sincerely, /s/ Craig D. Wilson Craig D. Wilson Senior Assistant Chief Accountant