SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Company Response from DLH Holdings Corp. (DLHC) (CIK 0000785557) (DLHC) — Sep 20, 2006

DLH Holdings Corp. (DLHC) (CIK 0000785557)
Date: Sept. 20, 2006 · CIK: 0000785557 · Accession: 0000950136-06-007860

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: August 24, 2006

Date
September 20, 2006
Author
Assistant Director
Form
CORRESP
Company
DLH Holdings Corp. (DLHC) (CIK 0000785557)

Letter

Mr. Larry Spirgel Assistant Director Division of Corporate Finance Securities and Exchange Commission Washington, D.C. 20549 Form 10-Q for the Fiscal Quarters ended December 31, 2005, March 31, 2006 And June 30, 2006 File No. 0-18492

Re: TeamStaff, Inc. Form 10-K for the Fiscal Year ended September 30, 2005

Dear Mr. Spirgel:

We are responding to your letter dated August 24, 2006 concerning your review of our supplemental response letter of August 8, 2006 on the above filings. Please be advised that we have been granted a ten (10) business day extension by Nicole Holden, Staff Accountant, to respond to your letter. We offer the following in response:

1. We agree that, in accordance with SFAS 141 paragraphs 37 and 39, the trademark of RS Staffing is an identifiable intangible asset not subject to amortization apart from goodwill. Although we believe the trade name has value in the government staffing segment, its value is approximately $370,000 based upon the historical spending on advertising and promotion limits. Due to the insignificance of the amount (.74% of total assets at September 30, 2005) we don't believe revising prior filings is material, and accordingly we will separate the trade name from goodwill in future filings in accordance with paragraphs 42 and 43 of SFAS 142 and will reclassify the items on the comparative balance sheet for the fiscal year ended September 30, 2005 (the year in which the acquisition was made). Because of the profitability of RS Staffing and the continued indefinite life of the trade name, management determined that an impairment in value did not exist at September 30, 2005. Additionally, impairment testing of both the trade name and goodwill will be performed by an outside valuation firm for the fiscal year ended September 30, 2006.

2. We agree with your comment and will enhance our discussion in the MD&A of the factors used by management in determining the realizability of the deferred tax asset in future filings.

In connection with our responses to the comments made by the staff of the Commission we acknowledge that:

1. we are responsible for the adequacy and accuracy of the disclosure in the filings;

2. staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and

3. we may not assert staff comments as a defense in any proceedings initiated by the Commission or any person under the federal security laws of the United States.

We believe that we have been responsive to your comments and questions. Please contact me at 732-748-3202 with additional comments or questions.

Very truly yours,
TEAMSTAFF, INC.

Show Raw Text
CORRESP
1
filename1.htm

                                                              September 20, 2006

Mr. Larry Spirgel
Assistant Director
Division of Corporate Finance
Securities and Exchange Commission
Washington, D.C.  20549

                                       Re:   TeamStaff, Inc.
                                             Form 10-K for the Fiscal Year ended
                                             September 30, 2005

                                             Form 10-Q for the Fiscal
                                             Quarters ended December 31,
                                             2005, March 31, 2006 And
                                             June 30, 2006

                                             File No.  0-18492

Dear Mr. Spirgel:

We are responding to your letter dated August 24, 2006 concerning your review of
our supplemental response letter of August 8, 2006 on the above filings. Please
be advised that we have been granted a ten (10) business day extension by Nicole
Holden, Staff Accountant, to respond to your letter. We offer the following in
response:

     1.   We agree that, in accordance with SFAS 141 paragraphs 37 and 39, the
          trademark of RS Staffing is an identifiable intangible asset not
          subject to amortization apart from goodwill. Although we believe the
          trade name has value in the government staffing segment, its value is
          approximately $370,000 based upon the historical spending on
          advertising and promotion limits. Due to the insignificance of the
          amount (.74% of total assets at September 30, 2005) we don't believe
          revising prior filings is material, and accordingly we will separate
          the trade name from goodwill in future filings in accordance with
          paragraphs 42 and 43 of SFAS 142 and will reclassify the items on the
          comparative balance sheet for the fiscal year ended September 30, 2005
          (the year in which the acquisition was made). Because of the
          profitability of RS Staffing and the continued indefinite life of the
          trade name, management determined that an impairment in value did not
          exist at September 30, 2005. Additionally, impairment testing of both
          the trade name and goodwill will be performed by an outside valuation
          firm for the fiscal year ended September 30, 2006.

     2.   We agree with your comment and will enhance our discussion in the MD&A
          of the factors used by management in determining the realizability of
          the deferred tax asset in future filings.

In connection with our responses to the comments made by the staff of the
Commission we acknowledge that:

          1.   we are responsible for the adequacy and accuracy of the
               disclosure in the filings;

          2.   staff comments or changes to disclosure in response to staff
               comments do not foreclose the Commission from taking any action
               with respect to the filings; and

          3.   we may not assert staff comments as a defense in any proceedings
               initiated by the Commission or any person under the federal
               security laws of the United States.

We believe that we have been responsive to your comments and questions. Please
contact me at 732-748-3202 with additional comments or questions.

                                 Very truly yours,

                                 TEAMSTAFF, INC.

                                 --------------------------
                                 Rick J. Filippelli