SEC Company Response from TEAM INC (TISI) (CIK 0000318833) (TISI) — Aug 12, 2005
TEAM INC (TISI) (CIK 0000318833)
Date: Aug. 12, 2005 · CIK: 0000318833 · Accession: 0001193125-05-167250
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CORRESP 1 filename1.htm Correspondence Filing August 12, 2005 United States Securities and Exchange Commission Mail Stop 4-7 450 Fifth Street, N. W. Washington, D. C. 20549 Attn: Larry Spirgel, Assistant Director RE: Team, Inc. Amendment No. 1 to Form 10-K for the fiscal year ended May 31, 2004 Filed April 14, 2005 Forms 10-Q for the quarter ended February 28, 2005 Filed April 15, 2005 File NO. 1-08604 Dear Mr. Spirgel: This will confirm our representation that we have three business segments—Team-Cooperheat-MQS (“TCM”), Team Mechanical Services (“TMS”) and Equipment Sales and Rentals (the “Climax” business). For purposes of segment disclosure, we aggregate TCM and TMS because of their similar economic characteristics. However, for purposes of the annual goodwill impairment test required by FAS #142, the reporting units are the individual segments. All recorded goodwill is attributable to TCM and to Climax, as a result of business acquisitions, and none is attributable to TMS. Therefore, impairment will be tested annually for TCM and for Climax. We would be pleased to address any further comments that the Commission has with respect to our filings. Very truly yours, /s/ Philip J. Hawk /s/ Ted W. Owen Philip J. Hawk Ted W. Owen Chief Executive Officer Senior Vice President-Chief Financial Officer