SEC Comment Letter for RPC INC (RES) (CIK 0000742278) (RES) — Jul 22, 2008
RPC INC (RES) (CIK 0000742278)
Date: July 22, 2008 · CIK: 0000742278 · Accession: 0000000000-08-036430
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE MAIL STOP 7010 July 22, 2008 Via U.S. Mail and Fax (404)321-5483 Mr. Ben M. Palmer Chief Financial Officer RPC, Inc. 2801 Buford Highway, Suite 520 Atlanta, GA 30329 Re: RPC, Inc. Form 10-K for the Fiscal Year Ended December 31, 2007 Filed March 4, 2008 Form 10-Q for the Quarterly Period Ended March 31, 2008 Filed May 1, 2008 File No. 1-08726
Dear Mr. Palmer: We have reviewed your Form 10-K for the Fiscal Year Ended December 31, 2007 and have the following comment. We have limited our review of your filing to those issues we have addressed in our comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please 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 filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Ben M. Palmer RPC, Inc. July 22, 2008 Page 2
Form 10-K for the fiscal year ended December 31, 2007 Note 1. Significant Accounting Policies
Revenue, page 38
1. We note disclosure indicating that your revenues are generated from services, equipment rentals and product sales. We also note Revenues and Costs of services rendered and goods sold are presented as single line items on your Consolidated Statement of Operations. Tell us how you considered Rule 5-03 of Regulation S-X and how you concluded the current presentation on your Consolidated Statement of Operations is appropriate. Closing Comments
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. 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 filing; staff comments or changes to disclosure in response to staff comments 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.
Mr. Ben M. Palmer RPC, Inc. July 22, 2008 Page 3
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Di vision of Corporation Finance in our review of your filing or in response to our comments on your filing. You may contact Bob Carroll at (202) 551-3362, or me at (202) 551-3489 if you have questions regarding comments on the financial statements and related matters. S i n c e r e l y , / s / B r a d S k i n n e r B r a d S k i n n e r Senior Assistant Chief Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE MAIL STOP 7010
July 22, 2008
Via U.S. Mail and Fax (404)321-5483
Mr. Ben M. Palmer
Chief Financial Officer RPC, Inc. 2801 Buford Highway, Suite 520 Atlanta, GA 30329
Re: RPC, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2007
Filed March 4, 2008 Form 10-Q for the Quarterly Period Ended March 31, 2008 Filed May 1, 2008
File No. 1-08726
Dear Mr. Palmer:
We have reviewed your Form 10-K for the Fiscal Year Ended December 31, 2007
and have the following comment. We have limited our review of your filing to those issues we have addressed in our comment. Where indicated, we think you should revise
your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please 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 filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Ben M. Palmer
RPC, Inc.
July 22, 2008 Page 2
Form 10-K for the fiscal year ended December 31, 2007
Note 1. Significant Accounting Policies
Revenue, page 38
1. We note disclosure indicating that your revenues are generated from services,
equipment rentals and product sales. We also note Revenues and Costs of services rendered and goods sold are presented as single line items on your Consolidated Statement of Operations. Tell us how you considered Rule 5-03 of Regulation S-X and how you concluded the current presentation on your Consolidated Statement of Operations is appropriate.
Closing Comments
As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision. 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
filing;
staff comments or changes to disclosure in response to staff comments 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.
Mr. Ben M. Palmer
RPC, Inc.
July 22, 2008 Page 3
In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing. You may contact Bob Carroll at (202) 551-3362, or me at (202) 551-3489 if you have questions regarding comments on the financial statements and related matters. S i n c e r e l y , / s / B r a d S k i n n e r B r a d S k i n n e r Senior Assistant Chief Accountant