SEC Comment Letter for NOBEL LEARNING COMMUNITIES INC (CIK 0000721237) — Apr 29, 2005
NOBEL LEARNING COMMUNITIES INC (CIK 0000721237)
Date: April 29, 2005 · CIK: 0000721237 · Accession: 0000000000-05-021053
AI Filing Summary & Sentiment
File numbers found in text: 000-27024
Referenced dates: April 11, 2005, February 25, 2005
Letter
April 15, 2005 Via U.S. Mail and Fax Mr. Thomas Frank Chief Financial Officer Nobel Learning Communities, Inc. 1615 West Chester Pike Suite 200 West Chester, PA 19382-6223 Form 10-Q for the quarter ended January 1, 2005 File No. 000-27024
RE: Nobel Learning Communities, Inc. Form 10-K for the fiscal year ended July 3, 2004 Filed September 15, 2004
Dear Mr. Frank: We have reviewed your supplemental response letter dated April 11, 2005 as well as the above referenced filings and have the following comments. As noted in our comment letter dated February 25, 2005, we have limited our review to your financial statements and related disclosures and will make no further review of your documents. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934.
Form 10-K for the year ended July 3, 2004
1. We note your responses to our previously issued comments 8 & 12. It is still unclear to us how you determined your operating segments and reporting units under the guidance of SFAS 131 and SFAS 142. In this regard, please address the following items:
* Clarify for us who you have identified as your chief operating decision maker and segment managers, as defined by paragraphs 12 and 14 of SFAS 131, respectively. * To further assist us in our understanding of your operations, please provide us with an organizational chart of the company that identifies the various levels of management and summarizes their responsibilities. * Please provide us with an example of all reports that are reviewed by your chief operating decision maker and segment management. * Please clarify your statement that "operating results for all schools are reviewed by management monthly by school..." Tell us who reviews these results and whether they are reviewed by either the chief operating decision maker or segment management. In light of this information, tell us why you believe that each school is neither an operating segment nor a reporting unit.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. You may contact Adam Washecka, Staff Accountant, at (202) 824-5569 or Melissa Hauber, Senior Staff Accountant, at (202) 942-2858 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 942-1990 if you have any other questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mail Stop 0407
April 15, 2005
Via U.S. Mail and Fax
Mr. Thomas Frank
Chief Financial Officer
Nobel Learning Communities, Inc.
1615 West Chester Pike
Suite 200
West Chester, PA 19382-6223
RE: Nobel Learning Communities, Inc.
Form 10-K for the fiscal year ended July 3, 2004
Filed September 15, 2004
Form 10-Q for the quarter ended January 1, 2005
File No. 000-27024
Dear Mr. Frank:
We have reviewed your supplemental response letter dated
April
11, 2005 as well as the above referenced filings and have the
following comments. As noted in our comment letter dated February
25, 2005, we have limited our review to your financial statements
and
related disclosures and will make no further review of your
documents. As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.
Form 10-K for the year ended July 3, 2004
1. We note your responses to our previously issued comments 8 &
12.
It is still unclear to us how you determined your operating
segments
and reporting units under the guidance of SFAS 131 and SFAS 142.
In
this regard, please address the following items:
* Clarify for us who you have identified as your chief operating
decision maker and segment managers, as defined by paragraphs 12
and
14 of SFAS 131, respectively.
* To further assist us in our understanding of your operations,
please provide us with an organizational chart of the company that
identifies the various levels of management and summarizes their
responsibilities.
* Please provide us with an example of all reports that are
reviewed
by your chief operating decision maker and segment management.
* Please clarify your statement that "operating results for all
schools are reviewed by management monthly by school..." Tell us
who
reviews these results and whether they are reviewed by either the
chief operating decision maker or segment management. In light of
this information, tell us why you believe that each school is
neither
an operating segment nor a reporting unit.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. You may contact
Adam Washecka, Staff Accountant, at (202) 824-5569 or Melissa
Hauber,
Senior Staff Accountant, at (202) 942-2858 if you have questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 942-1990 if you have any other
questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Thomas Frank
Nobel Learning Communities, Inc.
April 15, 2005
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