SEC Company Response from HANDY HARDWARE WHOLESALE INC (CIK 0000354053) — May 18, 2005
HANDY HARDWARE WHOLESALE INC (CIK 0000354053)
Date: May 18, 2005 · CIK: 0000354053 · Accession: 0000899078-05-000405
AI Filing Summary & Sentiment
File numbers found in text: 000-15708
Referenced dates: May 17, 2005
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<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
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Jenkens & Gilchrist
A PROFESSIONAL CORPORATION Austin, Texas
(512) 499-3800
Chicago, Illinois
1401 MCKINNEY (312) 425-3900
SUITE 260 Dallas, Texas
HOUSTON, TEXAS 77010-4034 (214) 855-4500
Los Angeles, California
(713) 951-3300 (310) 820-8800
FACSIMILE (713) 951-3314 Pasadena, California
(626) 578-7400
San Antonio, Texas
Lee Thompson (210) 246-5000
(713) 951-3342 Washington, D.C.
lthompson@jenkens.com www.jenkens.com (202) 326-1500
May 18, 2005
By EDGAR and facsimile 202-942-9531
Mr. Ryan Rohn
Staff Accountant
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 0510
450 5th Street, N.W. - Judiciary Plaza
Washington D.C. 20549-0405
Re: Handy Hardware Wholesale, Inc.
Form 8-K Item 4.01 filed April 28, 2005
Form 8-K/A Item 4.01 filed May 16, 2005
File No. 000-15708
Dear Mr. Rohn:
This letter responds to the comments of the Staff contained in your letter
dated May 17, 2005 regarding the above Form 8-K filed April 28, 2005 and the
Amended Form 8-K filed May 16, 2005. The responses included in this letter have
been numbered to correspond to the number of the Staff's comments. This letter
is being filed via EDGAR today.
1. IN CONSIDERATION OF OUR PRIOR COMMENT NUMBER TWO, WE HAVE NOTED THAT YOU HAVE
FILED YOUR FORM 10-Q FOR THE PERIOD ENDED MARCH 31, 2005, HOWEVER YOUR
DISCLOSURE STILL STATES, "CLYDE D. THOMAS WOULD CONTINUE TO ACT AS THE COMPANY'S
INDEPENDENT PUBLIC ACCOUNTANT AND ASSIST IN THE REVIEW OF THE COMPANY'S
FINANCIAL STATEMENTS FOR THE QUARTER ENDED MARCH 31, 2005..." YOUR DISCLOSURE
SHOULD INCLUDE A STATEMENT THAT DESCRIBES WHEN THE SERVICES OF YOUR FORMER
ACCOUNTANT HAVE ENDED. IN ADDITION, THE INTERIM PERIOD DATE IN YOUR DISCLOSURE
SHOULD BE UPDATED FOR THIS EFFECTIVE DATE.
We added a statement that Clyde D. Thomas' services ended effective May 13,
2005 and we updated the interim period date to reflect this date as well.
EXHIBIT 16:
6. TO THE EXTENT THAT YOU MAKE CHANGES TO THE FORM 8-K TO COMPLY WITH OUR
COMMENTS, PLEASE OBTAIN AND FILE AN UPDATED EXHIBIT 16.1 LETTER FROM THE FORMER
ACCOUNTANTS STATING WHETHER THE ACCOUNTANT AGREES WITH THE STATEMENTS MADE IN
YOUR REVISED FORM 8-K.
The Amended Form 8-K includes an updated Exhibit 16.1 letter from the
former accountants.
Please feel free to contact me at 713-951-3342 with any further questions
or comments. Thank you.
Very truly yours,
/s/ Lee Thompson
------------------
Lee Thompson
LT:at
cc: Ms. Tina S. Kirbie
Handy Hardware Wholesale, Inc.
8300 Tewantin Drive
Houston, TX 77061
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