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SEC Comment Letter for SUPERIOR GROUP OF COMPANIES, INC. (SGC) (CIK 0000095574) (SGC) — May 2, 2005

SUPERIOR GROUP OF COMPANIES, INC. (SGC) (CIK 0000095574)
Date: May 2, 2005 · CIK: 0000095574 · Accession: 0000000000-05-021342

AI Filing Summary & Sentiment

Referenced dates: March 14, 2005

Date
May 3, 2005
Author
??
Form
UPLOAD
Company
SUPERIOR GROUP OF COMPANIES, INC. (SGC) (CIK 0000095574)

Letter

May 3, 2005 By Facsimile and U.S. Mail Mr. Andrew D. Demott, Jr. Chief Financial Officer Superior Uniform Group, Inc. 10055 Seminole Blvd. Seminole, Florida 33772

RE: Form 10-K for the year ended December 31, 2004 Filed March 16, 2005 and April 28, 2005

Dear Mr. Demott:

We have reviewed your responses in your letter dated March 14, 2005 and have the following additional comment.

We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

Consolidated Statement of Cash Flows, page 15

1. We read your response to comment 3. We do not believe that the prepaid pension benefit costs that are recorded in your other assets line item meet the criteria described in paragraph 17(a) or (b) of SFAS 95. Specifically, the debt or equity instruments to which the funds are ultimately expended are not recorded in your financial statements. Given that defined benefit pension costs are a component of your overall compensation package, please revise future filings to record the amounts in operating activities.

As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please ensure the response letter provides any requested supplemental information. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment.

If you have any questions regarding these comments, please direct them to Anthony Watson, Staff Accountant, at (202) 551-3318 or, in his absence, to me at (202) 551-3843.

Sincerely,
George F. Ohsiek, Jr.
Branch Chief
??

Show Raw Text
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<TEXT>

										May 3, 2005

By Facsimile and U.S. Mail

Mr. Andrew D. Demott, Jr.
Chief Financial Officer
Superior Uniform Group, Inc.
10055 Seminole Blvd.
Seminole, Florida 33772

		RE:	Form 10-K for the year ended December 31, 2004
			Filed March 16, 2005 and April 28, 2005

Dear Mr. Demott:

	We have reviewed your responses in your letter dated March
14,
2005 and have the following additional comment.

	We welcome any questions you may have about our comment or on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

Consolidated Statement of Cash Flows, page 15

1. We read your response to comment 3.  We do not believe that the
prepaid pension benefit costs that are recorded in your other
assets
line item meet the criteria described in paragraph 17(a) or (b) of
SFAS 95.  Specifically, the debt or equity instruments to which
the
funds are ultimately expended are not recorded in your financial
statements.  Given that defined benefit pension costs are a
component
of your overall compensation package, please revise future filings
to
record the amounts in operating activities.

	As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please ensure the response letter provides any requested
supplemental
information.  Please file your response letter on EDGAR.  Please
understand that we may have additional comments after reviewing
your
response to our comment.

	If you have any questions regarding these comments, please
direct them to Anthony Watson, Staff Accountant, at (202) 551-3318
or, in his absence, to me at (202) 551-3843.

							Sincerely,

							George F. Ohsiek, Jr.
							Branch Chief
??

??

??

??

May 3, 2005
Page 2

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