SEC Comment Letter for IMPCO TECHNOLOGIES INC (CIK 0000790708) — Aug 4, 2005
IMPCO TECHNOLOGIES INC (CIK 0000790708)
Date: Aug. 4, 2005 · CIK: 0000790708 · Accession: 0000000000-05-040189
AI Filing Summary & Sentiment
Referenced dates: July 28, 2005
Letter
August 4, 2005 Zip+4 Code: 20077-9366 Via Fax & U.S. Mail Mr. Mariano Costamagna Chief Executive Officer Impco Technologies, Inc. 16804 Gridley Place Cerritos, California 90703
RE: Impco Technologies, Inc. (the “Company”) Form 10-K for the year ended December 31, 2004 File No. 1-15143
Dear Mr. Costamagna:
We received your letter dated July 28, 2005, and have the following comment.
Please respond within 15 business days. Pursuant to Rule 101(a)(3) of Regulation S-T, your response should be submitted in electronic form, under the label “corresp” with a copy to the staff.
Form 10-Q for the period ended March 31, 2005 Note 7. Business Acquisition
We have reviewed your response to our prior comment number 13 but do not believe that your response adequately addressed the concerns raised in our prior comment. As previously requested, please tell us and revise the notes to your financial statements to disclose the factors that contributed to a purchase price that re sulted in recognition of a significant amount of goodwill in connection with the BRC acquisition. Refer to the requirements of paragraph 51b of SFAS No.141. Additionally, as previously reque sted, please explain why no identifiable intangibles apart from goodwill were recognized in connection with this acquisition transaction.
Mr. Mariano Costamagna Impco Technologies, Inc. August 4, 2005 Page 2
You may contact Effie Simpson at (202) 551-3346 or , in her absence, the undersigned, at (202) 551-3813 if you have questions regarding comments on the financial statements and related matters. Please contact Max Webb, Assistant Director, at (202) 551-3818 with any other questions.
S i n c e r e l y ,
L i n d a C v r k e l B r a n c h C h i e f
Via facsimile: Tom M. Costales, CFO (562) 924-8069
Show Raw Text
August 4, 2005
Zip+4 Code: 20077-9366
Via Fax & U.S. Mail
Mr. Mariano Costamagna
Chief Executive Officer
Impco Technologies, Inc.
16804 Gridley Place
Cerritos, California 90703
RE: Impco Technologies, Inc. (the “Company”)
Form 10-K for the year ended December 31, 2004
File No. 1-15143
Dear Mr. Costamagna:
We received your letter dated July 28, 2005, and have the following comment.
Please respond within 15 business days. Pursuant to Rule 101(a)(3) of Regulation S-T, your
response should be submitted in electronic form, under the label “corresp” with a copy to the
staff.
Form 10-Q for the period ended March 31, 2005
Note 7. Business Acquisition
We have reviewed your response to our prior comment number 13 but do not believe that your
response adequately addressed the concerns raised in our prior comment. As previously
requested, please tell us and revise the notes to your financial statements to disclose the factors
that contributed to a purchase price that re sulted in recognition of a significant amount of
goodwill in connection with the BRC acquisition. Refer to the requirements of paragraph 51b of
SFAS No.141. Additionally, as previously reque sted, please explain why no identifiable
intangibles apart from goodwill were recognized in connection with this acquisition transaction.
Mr. Mariano Costamagna
Impco Technologies, Inc.
August 4, 2005
Page 2
You may contact Effie Simpson at (202) 551-3346 or , in her absence, the undersigned, at (202)
551-3813 if you have questions regarding comments on the financial statements and related
matters. Please contact Max Webb, Assistant Director, at (202) 551-3818 with any other
questions.
S i n c e r e l y ,
L i n d a C v r k e l
B r a n c h C h i e f
Via facsimile: Tom M. Costales, CFO
(562) 924-8069