SEC Comment Letter for ASCENT INDUSTRIES CO. (ACNT) (CIK 0000095953) (ACNT) — Dec 17, 2015
ASCENT INDUSTRIES CO. (ACNT) (CIK 0000095953)
Date: Dec. 17, 2015 · CIK: 0000095953 · Accession: 0000000000-15-058392
AI Filing Summary & Sentiment
Reasoning
Referenced dates: October 8, 2015
Letter
December 17 , 2015 Mail Stop 4631 Via E -Mail Craig C. Bram President and Chief Executive Officer Synalloy Corporation 775 Spartan Blvd., Suite 102 P.O. Box 5627 Spartanburg, S C 29304
Re: Synalloy Corporation Amendment No. 1 to Registration Statement on Form S-3 Filed August 19, 2015 File No. 333 -204850 Form 10 -K for Fiscal Year Ended January 3, 2015 Filed March 17, 2015 File No. 000 -19687 Form 10 -Q for Fiscal Quarter Ended July 4, 2015 Filed August 11, 2015 File No. 000 -19687 Form 10 -Q for Fiscal Quarter Ended October 3, 2015 Filed November 12, 2015 File No. 000 -19687
Dear Mr. Bram :
We have reviewed the above -captioned filings and your letter of correspondence dated December 10 , 2015 and have the following comment .
Synalloy Corporation Form 10 -K for Fiscal Year Ended January 3, 2015
Note 13: Industry Segments, page 46
1. Based on your response to comment 2 in our letter dated October 8, 2015 , as well as the information you provided in our telephone conversation on November 6, 2015, it does not appear that the products offered by Palmer are similar to the produc ts offered by BRISMET and Specialty. As such, please expand your disclosures to provide the required disclosures under ASC 280 -10-50-40.
Craig C. Bram Synalloy Corporation December 17 , 2015 Page 2
You may contact Ameen Hamady (Staff Accountant) at 202-551-3891 or Jeanne Baker (Staff Accountant ) at 202-551-3691 if you have questions regarding comments on the financial statements and related matters. Please contact Frank Pigott (Staff Attorney) at 202-551-3570 or me at 202-551-3397 with any other questions.
Sincerely,
/s/ Jay Ingram
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December 17 , 2015 Mail Stop 4631 Via E -Mail Craig C. Bram President and Chief Executive Officer Synalloy Corporation 775 Spartan Blvd., Suite 102 P.O. Box 5627 Spartanburg, S C 29304 Re: Synalloy Corporation Amendment No. 1 to Registration Statement on Form S-3 Filed August 19, 2015 File No. 333 -204850 Form 10 -K for Fiscal Year Ended January 3, 2015 Filed March 17, 2015 File No. 000 -19687 Form 10 -Q for Fiscal Quarter Ended July 4, 2015 Filed August 11, 2015 File No. 000 -19687 Form 10 -Q for Fiscal Quarter Ended October 3, 2015 Filed November 12, 2015 File No. 000 -19687 Dear Mr. Bram : We have reviewed the above -captioned filings and your letter of correspondence dated December 10 , 2015 and have the following comment . Synalloy Corporation Form 10 -K for Fiscal Year Ended January 3, 2015 Note 13: Industry Segments, page 46 1. Based on your response to comment 2 in our letter dated October 8, 2015 , as well as the information you provided in our telephone conversation on November 6, 2015, it does not appear that the products offered by Palmer are similar to the produc ts offered by BRISMET and Specialty. As such, please expand your disclosures to provide the required disclosures under ASC 280 -10-50-40. Craig C. Bram Synalloy Corporation December 17 , 2015 Page 2 You may contact Ameen Hamady (Staff Accountant) at 202-551-3891 or Jeanne Baker (Staff Accountant ) at 202-551-3691 if you have questions regarding comments on the financial statements and related matters. Please contact Frank Pigott (Staff Attorney) at 202-551-3570 or me at 202-551-3397 with any other questions. Sincerely, /s/ Jay Ingram Jay Ingram Legal Branch Chief Office of Manufacturing and Construction cc: Scott H. Richter LeClairRyan