SEC Company Response from LOGIC DEVICES INC (CIK 0000802851) — Aug 22, 2005
LOGIC DEVICES INC (CIK 0000802851)
Date: Aug. 22, 2005 · CIK: 0000802851 · Accession: 0000802851-05-000023
AI Filing Summary & Sentiment
Referenced dates: August 10, 2005, June 13, 2005
Letter
RE: SEC File No. 0-17187 Comment Letter dated August 10,
August 23, 2005
August 22, 2005
Ms. Heather C. Tress
United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 0610
Washington, D.C. 20549
Form 10-K for the Fiscal Year Ended September 30, 2004
Financial Statements, page 22
Inventories, page 29
1. Please refer to your response to prior comment 1 from our June 13, 2005 letter. We note that adjustment A in Exhibit A reduces your inventory reserve in 2002 for lower of cost or market adjustments or for excess reserve amounts. A write-down of inventory to the lower of cost or market at the close of a fiscal period creates a new cost basis that subsequently cannot be marked up based on changes in underlying facts and circumstances. Please tell us the nature of this decrease to your reserve and discuss your considerations of the above and footnote 2 to ARB 43 and SAB Topic 5.BB.
Response:
The amount of $1,530,700 shown in Exhibit A of our response to your letter dated June 13, 2005 should have been in "Write-Off" column, which has no effect on Cost of Sales. This amount was erroneously shown as a decrease to the reserve. We have included a revised Exhibit A.
Thank you.
Sincerely,
/s/ Kimiko
Milheim
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CORRESP 1 filename1.htm August 23, 2005 August 22, 2005 Ms. Heather C. Tress United States Securities and Exchange Commission Division of Corporation Finance Mail Stop 0610 Washington, D.C. 20549 RE: SEC File No. 0-17187 Comment Letter dated August 10, 2005 Form 10-K for the Fiscal Year Ended September 30, 2004 Financial Statements, page 22 Inventories, page 29 1. Please refer to your response to prior comment 1 from our June 13, 2005 letter. We note that adjustment A in Exhibit A reduces your inventory reserve in 2002 for lower of cost or market adjustments or for excess reserve amounts. A write-down of inventory to the lower of cost or market at the close of a fiscal period creates a new cost basis that subsequently cannot be marked up based on changes in underlying facts and circumstances. Please tell us the nature of this decrease to your reserve and discuss your considerations of the above and footnote 2 to ARB 43 and SAB Topic 5.BB. Response: The amount of $1,530,700 shown in Exhibit A of our response to your letter dated June 13, 2005 should have been in "Write-Off" column, which has no effect on Cost of Sales. This amount was erroneously shown as a decrease to the reserve. We have included a revised Exhibit A. Thank you. Sincerely, /s/ Kimiko Milheim Kimiko Milheim Chief Financial Officer Exhibit A Affects Cost of Sales: No effect on Beginning Increase to Decrease of Cost of Sales: Ending Reserve Reserve Note Reserve Note Write-off Note Reserve 2002 1,867,700 (1,530,700) A 337,000 2003 337,000 1,779,000 B (1,072,800) C 1,043,200 2004 1,043,200 250,000 D (250,300) E 1,042,900 NOTES: A - Write-off of inventory previously reserved. B - Increase in reserve during year based on analyses. C - Write-off of inventory reserved during fiscal 2003. D - Increase in reserve during year based on analyses. E - Write-off of inventory reserved during fiscal 2004.