SEC Comment Letter for TVI CORP (CIK 0000352079) — Jul 10, 2005
TVI CORP (CIK 0000352079)
Date: July 10, 2005 · CIK: 0000352079 · Accession: 0000000000-05-035056
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July 11, 2005
Via Facsimile and U.S. Mail (301-352-8818)
Karin McQuade
Chief Financial Office and Vice President-Finance
TVI Corporation
7100 Holladay Tyler Road
Glen Dale, MD 20769
RE: TVI Corporation
File No. 0-10449
Form 10-KSB for the fiscal year ended December 31, 2004
Dear Ms. McQuade:
We have reviewed the above referenced filing and have the
following comments. We have limited our review to the financial
statements and related disclosures included within these
documents.
Understand that the purpose of our review process is to assist you
in
your compliance with the applicable disclosure requirements and to
enhance the overall disclosure in your filings.
Please expand or revise your disclosure as requested. If
you
disagree, we will consider your explanation as to why our comments
are inapplicable or a revision is unnecessary. In some of our
comments, we may ask you to provide us with additional information
so
we may better understand your disclosure. Please be as detailed
as
necessary in your explanations. We look forward to working with
you
in these respects and welcome any questions you may have about any
aspects of our review.
Form 10-K for the fiscal year ended December 31, 2004
Net Sales, page 17
1. We note your prior expectation that a significant part of your
growth will come from foreign public health and first response
agencies as they increase their level of preparedness to accidents
and disastrous events. Please explain to us and in future filings
the
reason for the significant decrease in international sales during
2004. In addition, explain the reason for the further decrease in
international sales during 2005, and discuss whether you expect
this
trend to continue.
Financial Statements
Products Offered, page 28
2. In future filings, please provide additional quantitative
information on the revenue attributable to individual products and
product lines. Given the variety of products you sell, as
discussed
on page one, the significant increase in your revenue, and your
recent acquisition, additional quantitative information would
appear
useful. Refer to paragraph 37 of SFAS 131 for guidance. Explain
to
us how you will modify your disclosure in future filings or the
reason you believe additional disclosure is not necessary.
Other
3. We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
* * * *
Please file your response to our comments via EDGAR within
fifteen business days from the date of this letter. Please
understand that we may have additional comments after reviewing
your
response. You may contact Theresa Messinese at 202-551-3307 or
the
undersigned at 202-551-3812 with any questions.
Sincerely,
Michael Fay
Branch Chief
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TVI Corporation
July 11, 2005
Page 3
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