SEC Comment Letter for ST JOE Co (JOE) (CIK 0000745308) (JOE) — Dec 8, 2005
ST JOE Co (JOE) (CIK 0000745308)
Date: Dec. 8, 2005 · CIK: 0000745308 · Accession: 0000000000-05-061307
AI Filing Summary & Sentiment
Referenced dates: November 22, 2005
Letter
Mail Stop 4561 December 7, 2005 Mr. Peter S. Rummell Chief Executive Officer The St. Joe Company 245 Riverside Avenue, Suite 500 Jacksonville, FL 32202
Re: The St. Joe Company Form 10-K for Fiscal Year Ended December 31, 2005 Form 10-Q for Fiscal Quarter Ended March 31, 2005 Form 10-Q for Fiscal Quarter Ended June 30, 2005 File No. 1-10466
Dear Mr. Rummell:
We have reviewed your response letter dated November 22, 2005 and have the following additional comment.
Form 10-Q for Fiscal Quarter Ended September 30, 2005
Note 3. Discontinued Operations, page 9
1. We have reviewed your response to prior comment two. Please tell us how you applied the criteria set forth in paragraph 42 of SFAS and EITF 03-13 in determining that Advantis` results of operations should be reported in discontinued operations. Specifically, please address how you considered your continued relationship with GVA Advantis, the new entity, as disclosed in your Form 8-K filed October 25, 2005.
As appropriate, respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your response to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact Amanda Sledge, Staff Accountant, at (202) 551- 3473 or the undersigned at (202) 551-3403 if you have questions.
Sincerely,
Steven Jacobs
Accounting Branch Chief
Mr. Peter S. Rummell
The St. Joe Company
December 7, 2005
Page 2
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 4561
December 7, 2005
Mr. Peter S. Rummell
Chief Executive Officer
The St. Joe Company
245 Riverside Avenue, Suite 500
Jacksonville, FL 32202
Re: The St. Joe Company
Form 10-K for Fiscal Year Ended December 31, 2005
Form 10-Q for Fiscal Quarter Ended March 31, 2005
Form 10-Q for Fiscal Quarter Ended June 30, 2005
File No. 1-10466
Dear Mr. Rummell:
We have reviewed your response letter dated November 22, 2005 and
have the following additional comment.
Form 10-Q for Fiscal Quarter Ended September 30, 2005
Note 3. Discontinued Operations, page 9
1. We have reviewed your response to prior comment two. Please
tell
us how you applied the criteria set forth in paragraph 42 of SFAS
144
and EITF 03-13 in determining that Advantis` results of operations
should be reported in discontinued operations. Specifically,
please
address how you considered your continued relationship with GVA
Advantis, the new entity, as disclosed in your Form 8-K filed
October
25, 2005.
As appropriate, respond to this comment within 10 business
days
or tell us when you will provide us with a response. Please
furnish
a cover letter that keys your response to our comment and provides
any requested information. Detailed cover letters greatly
facilitate
our review. Please file your cover letter on EDGAR. Please
understand that we may have additional comments after reviewing
your
response to our comment.
You may contact Amanda Sledge, Staff Accountant, at (202)
551-
3473 or the undersigned at (202) 551-3403 if you have questions.
Sincerely,
Steven Jacobs
Accounting Branch Chief
Mr. Peter S. Rummell
The St. Joe Company
December 7, 2005
Page 2
</TEXT>
</DOCUMENT>