SEC Comment Letter for PARK AEROSPACE CORP (PKE) (CIK 0000076267) (PKE) — Mar 26, 2015
PARK AEROSPACE CORP (PKE) (CIK 0000076267)
Date: March 26, 2015 · CIK: 0000076267 · Accession: 0000000000-15-018085
AI Filing Summary & Sentiment
Reasoning
Letter
March 26, 2015 Via E -mail Brian E. Shore President and Chief Executive Officer Park Electrochemical Corp. 48 So uth Service Road Melville, NY 11747
Re: Park Electrochemical Corp. Form 10-K for the fiscal year ended March 2, 2014 Filed May 16, 2014 Form 8 -K filed January 8, 2015 File No. 001 -04415
Dear Mr. Shore :
We have reviewed your March 17, 2015 response to our comment letter 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 comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional co mments. Unless we note otherwise, our references to prior comments are to comments in our February 12, 2015 letter.
Form 8 -K filed on January 8, 2015
Exhibit 99.1, News Release dated January 8, 2015
Detailed operating information, page 8
1. We note your response to prior comment 7 that you recognize that your presentation is not consistent with Question 102.10 of the Q&A for Non -GAAP Financial Measures. As such, remove the columnar presentation of detailed operating information before special items in future filings.
You may contact Melissa Walsh, Staff Accountant , at (202) 551 -3224 if you have questions regarding comments on the financial statements and re lated matters. If you have any
Brian E. Shore Park Electrochemical Corp. March 26, 2015 Page 2
other questions, please contact Gabriel Eckstein, Staff Attor ney, at (202) 551 -3286. If you require further assistance, do not hesitate to contact me at (202) 551 -3488.
Sincerely,
/s/ Stephen Krikorian
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March 26, 2015 Via E -mail Brian E. Shore President and Chief Executive Officer Park Electrochemical Corp. 48 So uth Service Road Melville, NY 11747 Re: Park Electrochemical Corp. Form 10-K for the fiscal year ended March 2, 2014 Filed May 16, 2014 Form 8 -K filed January 8, 2015 File No. 001 -04415 Dear Mr. Shore : We have reviewed your March 17, 2015 response to our comment letter 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 comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional co mments. Unless we note otherwise, our references to prior comments are to comments in our February 12, 2015 letter. Form 8 -K filed on January 8, 2015 Exhibit 99.1, News Release dated January 8, 2015 Detailed operating information, page 8 1. We note your response to prior comment 7 that you recognize that your presentation is not consistent with Question 102.10 of the Q&A for Non -GAAP Financial Measures. As such, remove the columnar presentation of detailed operating information before special items in future filings. You may contact Melissa Walsh, Staff Accountant , at (202) 551 -3224 if you have questions regarding comments on the financial statements and re lated matters. If you have any Brian E. Shore Park Electrochemical Corp. March 26, 2015 Page 2 other questions, please contact Gabriel Eckstein, Staff Attor ney, at (202) 551 -3286. If you require further assistance, do not hesitate to contact me at (202) 551 -3488. Sincerely, /s/ Stephen Krikorian Stephen Krikorian Accounting Branch Chief