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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

Financial Reporting Internal Controls Business Model Clarity

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Summary

Reasoning

Date
August 12, 2005
Author
/s/ Philip J. Hawk
Form
CORRESP
Company
TEAM INC (TISI) (CIK 0000318833)

Letter

United States Securities and Exchange Commission Filed April 14, 2005 Forms 10-Q for the quarter ended February 28, 2005 Filed April 15, 2005 File NO. 1-08604

RE: Team, Inc.

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

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CORRESP
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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