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SEC Comment Letter for CAVALIER HOMES INC (CIK 0000789863) — Jul 7, 2005

CAVALIER HOMES INC (CIK 0000789863)
Date: July 7, 2005 · CIK: 0000789863 · Accession: 0000000000-05-034649

AI Filing Summary & Sentiment

Date
July 7, 2005
Author
Patricia Armelin
Form
UPLOAD
Company
CAVALIER HOMES INC (CIK 0000789863)

Letter

Mail Stop 07-10 July 7, 2005 Mr. Michael R. Murphy Cavalier Homes, Inc. 32 Wilson Boulevard 100 Addison, Alabama 35540

RE: Cavalier Homes, Inc. Form 8-K Item 4.01 Filed June 27, 2005 File No. 1-9792

Dear Mr. Murphy:

We have reviewed your filings and have the following comments. Where indicated, we think you should revise your documents 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. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.

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 on any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter.

1. We note that Deloitte & Touche LLP ("Deloitte") will resign following completion of its services related to the review of your interim financial statements for the period ended July 2, 2005. Please note that, at such time the review is completed and the relationship has actually terminated, an additional Item 4.01 Form 8-K will be required. The Form 8-K should address all of the disclosures required by Item 304 of Regulation S-K and an updated letter from the former accountant, filed as Exhibit 16, should be provided along with the filing. An Item 4.01 Form 8-K will also be required when you engage a new accountant. Please confirm to us your intentions in this regard.

*****

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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.

In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.

Please file your supplemental response via EDGAR in response to these comments within 5 business days of the date of this letter. Please note that if you require longer than 5 business days to respond, you should contact the staff immediately to request additional time. You may wish to provide us with marked copies of each amended filing to expedite our review. Direct any questions regarding the above to the undersigned at (202) 551-3747.

Sincerely,
Patricia Armelin
Staff Accountant
??

Show Raw Text
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<TEXT>

Mail Stop 07-10

	July 7, 2005

Mr. Michael R. Murphy
Cavalier Homes, Inc.
32 Wilson Boulevard 100
Addison, Alabama 35540

	RE:  	Cavalier Homes, Inc.
		Form 8-K Item 4.01
		Filed June 27, 2005
		File No. 1-9792

Dear Mr. Murphy:

      We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your documents 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.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      	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 on any other aspect
of
our review.  Feel free to call us at the telephone number listed
at
the end of this letter.

1. We note that Deloitte & Touche LLP ("Deloitte") will resign
following completion of its services related to the review of your
interim financial statements for the period ended July 2, 2005.
Please note that, at such time the review is completed and the
relationship has actually terminated, an additional Item 4.01 Form
8-K
will be required.  The Form 8-K should address all of the
disclosures
required by Item 304 of Regulation S-K and an updated letter from
the
former accountant, filed as Exhibit 16, should be provided along
with
the filing.  An Item 4.01 Form 8-K will also be required when you
engage a new accountant.  Please confirm to us your intentions in
this
regard.

*****

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in our review of your filing or in response
to
our comments on your filing.

      Please file your supplemental response via EDGAR in response
to
these comments within 5 business days of the date of this letter.
Please note that if you require longer than 5 business days to
respond, you should contact the staff immediately to request
additional time.  You may wish to provide us with marked copies of
each amended filing to expedite our review.  Direct any questions
regarding the above to the undersigned at (202) 551-3747.

							Sincerely,

								Patricia Armelin
								Staff Accountant
??

??

??

??

Mr. Michael R. Murphy
Cavalier Homes, Inc.
July 7, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0710

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>