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corresp

December 22, 2005

Via Electronic Submission

Ms. Angela Crane

Securities and Exchange Commission

100 F Street, N. E.

Washington, DC 20549

    RE:

    File No. 1-12123

    Staff letter dated November 30, 2005 regarding JLG Industries, Inc.

    Form 10-K for the fiscal year ended July 31, 2005

    Form 8-K filed September 23, 2005

    File No. 1-12123

Dear Ms. Crane:

On behalf of JLG Industries, Inc., a Pennsylvania corporation (the “Company”), we are providing the
following responses to the comment letter dated November 30, 2005 from the staff (the “Staff”) of
the Securities and Exchange Commission (the “Commission”) regarding the Company’s Form 10-K for the
fiscal year ended July 31, 2005 that was filed with the Commission on October 3, 2005, and the
Company’s Form 8-K that was filed with the Commission on September 23, 2005. The responses set
forth below are numbered to correspond to the numbered comments in the Staff’s comment letter,
which have been reproduced here in bold for ease of reference. Amounts are stated in thousands
unless otherwise indicated.

Form 10-K for the fiscal year ended July 31, 2005

Item 7 – Management’s Discussion and Analysis of Financial Condition and Results of Operations,
page F-12

Results of Operations, page 13

1. When you cite more than one factor in explaining the change in a financial statement line
item the amounts of the individual factors cited, including offsetting factors should be
separately quantified. Please apply throughout MD&A in future
filings.

Response:

We have included the amounts related to factors cited in our MD&A when the factors can be precisely
quantified. When this is not practical, we have followed the policy of listing contributing
factors in order of relative importance, regardless of whether they are quantified by a dollar
amount, and have included the following disclosure in MD&A:

“In the discussion and analysis of financial condition and results of operations that
follows, we attempt to list contributing factors in order of significance to the point
being addressed.”

While the specific impact of individual factors cannot always be precisely quantified, we will
endeavor to improve our disclosures in this area throughout MD&A prospectively.

Note 1 – Summary of Significant Accounting Policies, page 32

Revenue Recognition, page 32

2.
We note for certain sales transactions you recognize revenue prior to the time the customer
takes physical possession. Please confirm that the customer has the risk of loss in the event
of theft or physical destruction or damage to the product.

Response:

As explained more fully below, we confirm that the customer has the risk of loss in the event of
theft or loss.

We disclosed the following in the Notes to our Consolidated Financial Statements, Note 1 —
Summary of Significant Accounting Polices, Revenue Recognition:

“Sales of non-military equipment and service parts are unconditional sales that are
recorded when product is shipped and invoiced to independently owned and operated
distributors and customers. Normally our sales terms are “free-on-board” shipping point
(FOB shipping point). However, certain sales, including our All-Terrain Lifter, Army System
(“ATLAS”) brand of military telehandler products, may be invoiced prior to the time
customers take physical possession. In such cases, revenue is recognized only when the
customer has a fixed commitment to purchase the equipment, the equipment has been completed
and made available to the customer for pickup or delivery, and the customer has requested
that we hold the equipment for pickup or delivery at a time specified by the customer. In
such cases, the equipment is invoiced under our customary billing terms, title to the
equipment and risk of ownership passes to the customer upon invoicing, the equipment is
segregated from our inventory and identified as belonging to the customer, and we have no
further obligations under the order other than customary post-sales support activities. In
the instances that our shipping terms

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are “shipping point destination,” revenue is recorded at the time the goods reach our
customers.”

A portion of our military sales (ATLAS brand) are recorded as bill and hold transactions. The
military inspects the products at the Company location and then provides written documentation to
the Company whereby it accepts risk of loss in the event of theft or physical destruction or
damage to the product. Supplementally, we disclose to the Staff that revenue recorded under the
bill and hold method for the fiscal year ended July 31, 2005 was
1.2% of total revenues.

3. Please tell us and revise future filings to describe the significant terms and conditions of
your sales to distributors, including a description of the specific incentives and other
compensation that you grant. Tell us if there are any cancellation provisions in the dealers’
contracts either for cancellation of purchases or cancellation of the relationship. Also tell
us and revise future filings to address how you account for returns, price protection, price
concessions, and other sales incentives, as applicable.

Response:

As disclosed in our Form 10-K on page 5:

“Our products are marketed to over 3,500 locations worldwide through independent rental
companies and distributors that rent and sell our products and provide service support, as
well as through other sales and service branches or organizations in which we hold equity
positions.”

With respect to our sales to distributors, we supplementally disclose to the Staff that JLG sells
products and parts to distributors at JLG’s published prices, with a discount structure that is
typically negotiated with each distributor, and terms in effect at the date of shipment. In
addition, these pricing structures may include specific volume-based incentives, which are
calculated and paid or credited on account as a percentage of actual purchases. We account for
these incentives as sales discounts at the time of revenue recognition as a direct reduction of
sales. Sales terms to distributors are normally FOB shipping point and credit terms are included
on the invoice.

Distributor agreements generally provide that no orders may be cancelled by a distributor after
acceptance by JLG without the written consent of JLG. Orders may also be cancelled if the
agreement is terminated. The distributor agreement may be terminated if the distributor files for
bankruptcy, if JLG notifies the distributor that it disapproves of any change made in the
distributor’s ownership or key management or by either party to the agreement giving the other
party 60 days’ written notice.

Generally, we do not provide price protection, such as guaranteed residual or trade values, and we
do not provide a return right to our distributors or customers and, therefore, do not have a sales return accrual.

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We will add the following to our revenue recognition accounting policy disclosure prospectively:

The terms for sales transactions with some of our distributors and customers may include
specific volume-based incentives, which are calculated and paid or credited on account as a
percentage of actual purchases. We account for these incentives as sales discounts at the
time of revenue recognition as a direct reduction of sales. We review our accrual for
sales incentives on a quarterly basis and any adjustments are reflected in current
earnings.

4. As a related matter please provide us with and revise future filings to include a valuation
and qualifying accounts schedule as required by Rule 12-09 of Regulations S-X for all material
valuation accounts, including your allowance for sales returns and discounts and doubtful
accounts.

Response:

As previously noted, we do not provide for a right of return on our products. As a result, we do
not have sales returns and, therefore, allowances for sales returns. We did not include the
schedule for allowances for doubtful accounts because we determined that the amounts were not
material. We supplementally disclose to the Staff that our allowance for doubtful accounts reserve
was $11.3 million as of July 31, 2005 which represents only 1.3% of total current assets and only
2.6% of the total gross receivables balance. The $7.4 million reserve associated with our notes
receivables as of July 31, 2005 represents only 0.6% of total assets as of July 31, 2005. In
addition, both reserves are disclosed in our Form 10-K.

5. Please address the following related to the gains on sale of used equipment:

    •

    Describe to us the material terms of the rental purchase guarantee agreements
entered into with your customers.

    •

    Tell us in greater detail how you account for these transactions and cite the
accounting literature upon which you rely.

    •

    Tell us the useful life you assigned to this equipment and where you record the
related depreciation

    •

    Describe how you test the assets for impairment pursuant to SFAS 144.

    We may have additional comments after reviewing your response.

Response:

This comment appears to blend comments regarding both used equipment and equipment held for rental.

Transactions related to the sale of non-rental used
equipment are reported as sales and cost of sales in
our consolidated income statement. Used equipment is included with

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finished goods in inventory
at the lower of cost or market in our
consolidated balance sheet.

Conversely, equipment held for rental represents the Company’s own fleet of rental equipment which is rented to
our customers. Revenue generated from the rental of equipment held for rental is disclosed as rental revenue in the consolidated income statement. The related
depreciation expense is disclosed with cost of sales. Equipment held for rental and related
accumulated depreciation are disclosed separately in our consolidated balance sheet. Transactions
related to the sale of equipment held for rental are reported as sales and cost of sales in our
consolidated income statement and as gains on the sale of equipment held for rental in our
consolidated statement of cash flows.

The Company enters into three types of rental agreements, Rent-to-Rent, Rental Purchase Options
(RPO) and Rental Purchase Guarantees (RPG). An explanation of each with the related accounting is
as follows:

Rent-to-Rent – As disclosed in Item 1 of our Form 10-K on page 4, the Company maintains a rental
fleet to support its rental company customers’ demands for short-term equipment requirements.
These contracts provide for monthly rentals of access equipment.

Rental Purchase Options – The Company enters into RPO contracts with its customers usually for
rental periods of 12 months or less with an option to purchase the equipment. The terms of the
agreements are structured to encourage the lessee to purchase the equipment during or at the end of
the rental period.

For both of the above types of rental contracts, we disclose our revenue recognition policy in the
Notes to our Consolidated Financial Statements, Note 1 — Summary of Significant Accounting
Polices.

“In addition, net revenues include rental revenues earned on the lease of equipment held
for rental. Rental revenues are recognized in the period earned over the lease term.”

As disclosed in the Notes to our Consolidated Financial Statements, Note 1 — Summary of
Significant Accounting Polices, depreciation of equipment held for rental is computed using the
straight-line method, based on useful lives of three to seven years. The depreciation expense is
recorded in cost of sales.

The disclosure related to the conversion of a rental to a sale is as described above. Sales of
equipment held for rental are reported as sales and cost of sales in our consolidated income
statement and, based upon the guidance in SFAS 95, as gains on the sale of equipment held for
rental in our consolidated statement of cash flows.

Pursuant to SFAS No. 144, “Accounting for the Impairment or Disposal of Long-Lived Assets,” the
Company reviewed its Equipment Held for Rental for any indicators of

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impairment at July 31, 2005 and a determination was made that none existed. We based our
conclusion upon a review of the following events or changes in circumstances which may indicate
that the carrying amount of the asset may not be recoverable.

    •

    A significant decrease in the market price of long-lived assets.

    •

    A significant adverse change in the extent or manner in which a long-lived asset is
used, or in its physical condition.

    •

    A significant adverse change in legal factors or in the business climate that could
affect the value of a long-lived asset.

    •

    An accumulation of costs significantly in excess of the amount originally expected for
the acquisition or construction of a long-lived asset.

    •

    A current period operating or cash flow loss, combined with a history of operating or
cash flow losses or a projection or forecast that demonstrates continuing losses
associated with the use of a long-lived asset.

We based our determination upon the facts that current market prices for used equipment and our
utilization rates remain strong and the Company reported gains on sales of equipment held for
rental.

Rental Purchase Guarantees – The third type of rental contract the Company enters into with its
customers is where we lease equipment to the customer under terms that require not only periodic
rental payments but also full payment for the equipment at a fixed price on a date certain. We
disclose in our revenue recognition policy in the Notes to our Consolidated Financial Statements,
Note 1 — Summary of Significant Accounting Polices.

“Revenue from certain equipment lease contracts is accounted for as sales-type leases. The
present value of all payments, net of executory costs (such as legal fees), is recorded as
revenue and the related cost of the equipment is charged to cost of sales. The associated
interest is recorded over the term of the lease using the interest method.”

The resulting receivable is classified with Trade Accounts and Finance Receivables on the
consolidated balance sheet as further detailed in Note 3 to the consolidated financial statements.

In accounting for Rental Purchase Guarantees, the Company first reviews the general requirements of
SAB 101:

Revenue generally is realized or realizable and earned when all of the following criteria are
met:

    1.

    Persuasive evidence of an arrangement exists

    The Company has a rental agreement with a definitive and legal obligation of the
customer to buy the equipment upon expiration of the rental.

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    2.

    Delivery has occurred or services have been rendered

    The Company has delivered the fully operational equipment.

    3.

    The seller’s price to the buyer is fixed or determinable, and

    The rental agreement fixes the monthly rental and contains a fixed sale price at end of
rental.

    4.

    Collectibility is reasonably assured.

    The Company has reviewed the credit worthiness of the customer and determined that
collectibility is reasonably assured.

The Company followed the guidance in SFAS 13, “Accounting for Leases” and determined that the
transaction met the criteria to qualify as a sales type lease. Sales
type leases are “leases that
give rise to manufacturer’s or dealer’s profit (or loss) to the lessor” and that meet one or more
of the criteria in paragraph 7 of SFAS 13 and both of the criteria in paragraph 8.

A lease is a capital lease if it meets any one of the following criteria; otherwise, it is an
operating lease:

    1.

    Ownership is transferred to the lessee by the end of the lease term.

    The purchase guarantee assures transfer of ownership.

    2.

    The lease contains a bargain purchase option.

    The agreement does not provide for a bargain purchase option.

    3.

    The lease term is at least 75% of the propert