SEC Comment Letter for MULTIBAND CORP (CIK 0000732412) — Aug 2, 2005
MULTIBAND CORP (CIK 0000732412)
Date: Aug. 2, 2005 · CIK: 0000732412 · Accession: 0000000000-05-039750
AI Filing Summary & Sentiment
Referenced dates: July 11, 2005, July 12, 2005
Letter
Via U.S. Mail and Fax (763) 504-3060 Steven Bell Chief Financial Officer Multiband Corp 9449 Science Center Drive New Hope, MN 55428 File No. 0-13529
Re: Multiband Corp Form 10-K/A for the year ended December 31, 2004 Filed July 20, 2005
Dear Mr. Bell:
We have reviewed your supplemental response letter dated July 12, 2005 as well as your filing and have the following comment. As noted in our comment letter dated July 11, 2005, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.
Form 10-K/A for the year ended December 31, 2004
1. We refer to your disclosure in note 16 `Business Segments`. It appears that the measure of profit or loss for which your CODM makes operating decisions and assesses segment performance is `Income (loss) from operations`. Our review of your MD&A shows that you fail to discuss the profitability measure of your segments consistent with the measure disclosed in your SFAS 131 segment information as is required by Section 501.06 of the Codification of Financial Reporting Policies. Please confirm to us that you will comply with this comment in future filings.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. You may contact Al Rodriguez, Staff Accountant, at (202) 551-3370 or Carlos Pacho, Senior Assistant Chief Accountant, at (202) 551-3835 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 with any other questions. Please file your response letter on EDGAR.
Sincerely,
/s/ Carlos Pacho
for Larry Spirgel
Assistant Director
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<TEXT>
Mail Stop 3561 August 2, 2005
Via U.S. Mail and Fax (763) 504-3060
Steven Bell
Chief Financial Officer
Multiband Corp
9449 Science Center Drive
New Hope, MN 55428
Re: Multiband Corp
Form 10-K/A for the year ended December 31, 2004
Filed July 20, 2005
File No. 0-13529
Dear Mr. Bell:
We have reviewed your supplemental response letter dated July 12,
2005 as well as your filing and have the following comment. As
noted
in our comment letter dated July 11, 2005, we have limited our
review
to your financial statements and related disclosures and do not
intend to expand our review to other portions of your documents.
Form 10-K/A for the year ended December 31, 2004
1. We refer to your disclosure in note 16 `Business Segments`. It
appears that the measure of profit or loss for which your CODM
makes
operating decisions and assesses segment performance is `Income
(loss) from operations`. Our review of your MD&A shows that you
fail
to discuss the profitability measure of your segments consistent
with
the measure disclosed in your SFAS 131 segment information as is
required by Section 501.06 of the Codification of Financial
Reporting
Policies. Please confirm to us that you will comply with this
comment in future filings.
* * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. You may contact
Al
Rodriguez, Staff Accountant, at (202) 551-3370 or Carlos Pacho,
Senior Assistant Chief Accountant, at (202) 551-3835 if you have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551-3810 with any other
questions. Please file your response letter on EDGAR.
Sincerely,
/s/ Carlos Pacho
for Larry Spirgel
Assistant Director
??
??
??
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Steven Bell
Multiband Corp
August 2, 2005
Page 1 of 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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