SEC Company Response from RPC INC (RES) (CIK 0000742278) (RES) — Sep 5, 2008
RPC INC (RES) (CIK 0000742278)
Date: Sept. 5, 2008 · CIK: 0000742278 · Accession: 0000914062-08-000442
AI Filing Summary & Sentiment
File numbers found in text: 001-08726
Referenced dates: August 22, 2008, August 4, 2008
Letter
VIA EDGAR Division of Corporation Finance United States Securities and Exchange Commission Filed May 1, 2008 Response letter Dated August 4, 2008 File No. 001-08726 Your comment letter dated August 22, 2008
Dear Mr. Skinner:
Below is our response to your comment raised in the above referenced letter.
Form 10-K for the fiscal year ended December 31, 2007
Note 1. Significant Accounting Policies
Revenue, page
1.
We note your response to our prior comment 1. Tell us if your specialized equipment rental comprises 10% or more of your revenue. If so, explain why you believe your current presentation complies with Rule 5-03(b)(1)(c) of Regulation S-X which requires separate disclosure of income from rentals if income derived from that category is more than 10% of total income.
RESPONSE
Our specialized equipment rental service can be segregated into two components: (1) charges for customer usage, without our direct involvement, of our owned equipment and (2) ancillary services including but not limited to pipe inspection, cleaning, preparing, transporting, repairs and maintenance in accordance with the rigorous safety and performance standards mandated by the industry. Total revenues from specialized equipment rental service have ranged from 10% to 13% of our consolidated revenues in each of the three years ended December 31, 2007. However, revenues from component (1) have never been greater than 10% of our consolidated revenues. Consistent with our peers in the industry, we consider ourselves to be in the oilfield services business and believe that substantially all of our revenues are derived from services. For that reason, after considering Rule 5-03 of Regulation S-X, we concluded that presentation of single line items for “Revenues” and “Cost of revenues” is appropriate.
Please do not hesitate to contact me at (404) 321-2149 if you need further information.
Sincerely,
/s/ Ben M.
Palmer
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CORRESP
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RPC
Incorporated, 2170 Piedmont Road NE., Atlanta,
GA 30324 Telephone: (404)
321-2140 Facsimile: (404)
321-5483
VIA
EDGAR
September
5, 2008
Mr. Brad
Skinner
Senior
Assistant Chief Accountant
Division
of Corporation Finance
United
States Securities and Exchange Commission
100 F
Street, N.E.
Washington,
DC 20549-7010
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
Response
letter Dated August 4, 2008
File
No. 001-08726
Your
comment letter dated August 22, 2008
Dear Mr.
Skinner:
Below is
our response to your comment raised in the above referenced letter.
Form 10-K for the fiscal
year ended December 31, 2007
Note 1. Significant
Accounting Policies
Revenue, page
38
1.
We
note your response to our prior comment 1. Tell us if your
specialized equipment rental comprises 10% or more of your
revenue. If so, explain why you believe your current
presentation complies with Rule 5-03(b)(1)(c) of Regulation S-X which
requires separate disclosure of income from rentals if income derived from
that category is more than 10% of total
income.
RESPONSE
Our
specialized equipment rental service can be segregated into two
components: (1) charges for customer usage, without our direct
involvement, of our owned equipment and (2) ancillary services including but not
limited to pipe inspection, cleaning, preparing, transporting, repairs and
maintenance in accordance with the rigorous safety and performance standards
mandated by the industry. Total revenues from specialized equipment
rental service have ranged from 10% to 13% of our consolidated revenues in each
of the three years ended December 31, 2007. However, revenues from
component (1) have never been greater than 10% of our consolidated
revenues. Consistent with our peers in the industry, we consider
ourselves to be in the oilfield services business and believe that substantially
all of our revenues are derived from services. For that reason, after
considering Rule 5-03 of Regulation S-X, we concluded that presentation of
single line items for “Revenues” and “Cost of revenues” is
appropriate.
Please do
not hesitate to contact me at (404) 321-2149 if you need further
information.
Sincerely,
/s/ Ben M.
Palmer
Ben M.
Palmer
Vice
President and Chief Financial Officer
cc: Mr.
Bob Carroll