SEC Company Response from WOLVERINE TUBE INC (CIK 0000821407) — Aug 4, 2005
WOLVERINE TUBE INC (CIK 0000821407)
Date: Aug. 4, 2005 · CIK: 0000821407 · Accession: 0000950144-05-008235
AI Filing Summary & Sentiment
Letter
United States Securities and Exchange Commission Wolverine Tube, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 Form 10-Q for Fiscal Quarter Ended March 31, 2005 File No. 1-12164
RE:
Dear Mr. Decker:
As requested by Mr. Nate Cheney of your office, included below is the form of supplemental information that Wolverine intends to provide in its next Form 10-Q filing related to the enterprise-wide revenue disclosures required by paragraphs 37 and 103 of SFAS 131 and Item 101(c)(i) of Regulation S-K. This information is provided as additional information to our response letter to you dated July 18, 2005 related to your follow-up letter of July 1, 2005 which contains the comments of the SEC staff on the above referenced filings.
Sales by segment by product line are as follows (in thousands):
For the year
ended
For the year ended
For the year ended
Product Line
December 31, 2004
December 31, 2003
December 31, 2002
Commercial products:
Tube products
$ 362,955
$ 276,367
$ 257,107
Fabricated products
130,117
102,576
98,726
Other products
77,594
63,528
65,401
Subtotal
570,666
442,471
421,234
Wholesale products
165,215
115,112
93,938
Rod, Bar & Other products
61,994
38,741
35,351
Total
$ 797,875
$ 596,324
$ 550,523
Included in other commercial products above are the Company’s Metal Joining and Copper Alloy products lines as individually each of those product lines represent less than 10% of the Company’s total sales for each year.
* * * * *
In responding to your comments, Wolverine acknowledges that:
•
The Company is responsible for the adequacy and accuracy of the disclosure in its Securities and Exchange Commission 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 comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Finally, we would ask that if the SEC staff is not satisfied with the actions and modifications which the Company is making pursuant to your request, as outlined above, we would ask for a telephonic discussion to move this matter to closure. I can be reached directly at 256-580-3625 or through my assistant Judi Stiger at 256-580-3958. In addition, please note that I will be out of the country from Friday August 12, 2005 returning on Monday August 29, 2005 and may not have access to my e-mail or voice mail. In my absence, please contact Jennifer Brinkley at 256-580-3982.
Yours very truly,
/s/ Thomas B. Sabol
Thomas B. Sabol
Senior Vice President,
Chief Financial Officer
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CORRESP
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Wolverine Tube, Inc.
August 4, 2005
Mr. Rufus Decker
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
RE:
Wolverine Tube, Inc.
Form 10-K for Fiscal Year Ended December 31, 2004
Form 10-Q for Fiscal Quarter Ended March 31, 2005
File No. 1-12164
Dear Mr. Decker:
As requested by Mr. Nate Cheney of your office, included below is the form of supplemental
information that Wolverine intends to provide in its next Form 10-Q filing related to the
enterprise-wide revenue disclosures required by paragraphs 37 and 103 of SFAS 131 and Item
101(c)(i) of Regulation S-K. This information is provided as additional information to our
response letter to you dated July 18, 2005 related to your follow-up letter of July 1, 2005 which
contains the comments of the SEC staff on the above referenced filings.
Sales by segment by product line are as follows (in thousands):
For the year
ended
For the year ended
For the year ended
Product Line
December 31, 2004
December 31, 2003
December 31, 2002
Commercial products:
Tube products
$
362,955
$
276,367
$
257,107
Fabricated products
130,117
102,576
98,726
Other products
77,594
63,528
65,401
Subtotal
570,666
442,471
421,234
Wholesale products
165,215
115,112
93,938
Rod, Bar & Other products
61,994
38,741
35,351
Total
$
797,875
$
596,324
$
550,523
Included in other commercial products above are the Company’s Metal Joining and Copper Alloy
products lines as individually each of those product lines represent less than 10% of the Company’s
total sales for each year.
* * * * *
In responding to your comments, Wolverine acknowledges that:
•
The Company is responsible for the adequacy and accuracy of the disclosure in its
Securities and Exchange Commission 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 comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.
Finally, we would ask that if the SEC staff is not satisfied with the actions and
modifications which the Company is making pursuant to your request, as outlined above, we would ask
for a telephonic discussion to move this matter to closure. I can be reached directly at
256-580-3625 or through my assistant Judi Stiger at 256-580-3958. In addition, please note that I
will be out of the country from Friday August 12, 2005 returning on Monday August 29, 2005 and may
not have access to my e-mail or voice mail. In my absence, please contact Jennifer Brinkley at
256-580-3982.
Yours very truly,
/s/ Thomas B. Sabol
Thomas B. Sabol
Senior Vice President,
Chief Financial Officer