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SEC Comment Letter for LSI INDUSTRIES INC (LYTS) (CIK 0000763532) (LYTS) — Mar 29, 2007

LSI INDUSTRIES INC (LYTS) (CIK 0000763532)
Date: March 29, 2007 · CIK: 0000763532 · Accession: 0000000000-07-015707

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File numbers found in text: 000-13375

Date
March 29, 2007
Author
Jay Webb
Form
UPLOAD
Company
LSI INDUSTRIES INC (LYTS) (CIK 0000763532)

Letter

Mail Stop 6010 March 29, 2007 Mr. Ronald S. Stowell Chief Financial Officer LSI Industries, Inc. 10000 Alliance Road Cincinatti, Ohio 45242

RE: LSI Industries, Inc. Form 10-K for the fiscal year ended June 30, 2006 Filed September 8, 2006 File No. 000-13375

Dear Mr. Stowell:

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Pl ease be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.

Please understand that the purpose of our re view 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the period ending June 30, 2006

Report of Independent Registered Public Accounting Firm, page S-15

1. We note your financial statements contain an unsigned audit report for the fiscal year ended June 30, 2005. Please revise th e filing to include a signed report of your Independent Registered Public A ccounting Firm. Refer to Item 302 of Regulation S-T, which addresses signatures in electronic filings.

Ronald S. Stowell LSI Industries, Inc. March 29, 2007 Page 2 As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your response that keys your responses to our comments and provides any requested information. Detailed cover le tters greatly facilitate our re view. Please file your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your 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 in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating 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 filings;

‚ 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 comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.

You may contact Dennis Hult, Staff Accountant, at (202) 551-3618 or myself if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3603 with any other questions. In this regard, do not hesitate to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-3554.

S i n c e r e l y ,

J a y W e b b Reviewing Accountant

Show Raw Text
Mail Stop 6010

March 29, 2007

Mr. Ronald S. Stowell
Chief Financial Officer
LSI Industries, Inc.
10000 Alliance Road
Cincinatti, Ohio 45242

 RE: LSI Industries, Inc.
  Form 10-K for the fiscal  year ended June 30, 2006
  Filed September 8, 2006
  File No. 000-13375

Dear Mr. Stowell:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in future filings in response to these
comments.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.

 Please understand that the purpose of our re view 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 on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the period ending June 30, 2006

Report of Independent Registered Public Accounting Firm, page S-15

1. We note your financial statements contain an unsigned audit report for the fiscal
year ended June 30, 2005.  Please revise th e filing to include a signed report of
your Independent Registered Public A ccounting Firm.  Refer to Item 302 of
Regulation S-T, which addresses signatures in electronic filings.

Ronald S. Stowell
LSI Industries, Inc.
March 29, 2007 Page 2
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a cover letter with your
response that keys your responses to our  comments and provides any requested
information.  Detailed cover le tters greatly facilitate our re view.  Please file your cover
letter on EDGAR.  Please understand that we may have additional comments after reviewing your 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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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
filings;

‚ 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Dennis Hult, Staff Accountant, at (202) 551-3618 or myself if
you have questions regarding comments on the financial statements and related matters.
Please contact me at (202) 551-3603 with any other questions.  In this regard, do not
hesitate to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-3554.

        S i n c e r e l y ,

        J a y  W e b b
        Reviewing Accountant