SEC Comment Letter for WILLAMETTE VALLEY VINEYARDS INC (WVVI, WVVIP) (CIK 0000838875) (WVVI) — Jan 9, 2007
WILLAMETTE VALLEY VINEYARDS INC (WVVI, WVVIP) (CIK 0000838875)
Date: Jan. 9, 2007 · CIK: 0000838875 · Accession: 0000000000-07-001137
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 15, 2006
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0404 DIVISION OF CORPORATION FINANCE Mail Stop 3561 January 9, 2007 Mr. James W. Bernau President Willamette Valley Vineyards, Inc. 8800 Enchanted Way, SE Turner, OR 97392
Re: Willamette Valley Vineyards, Inc. Form 10-KSB for the Fiscal Year Ended December 31, 2005 Filed March 31, 2006 Form 10-Q for the Quarterly Period Ended September 30, 2006 Filed November 14, 2006 File No. 0-21522
Dear Mr. Bernau:
We have reviewed your response letter dated December 15, 2006 and have the following comments. Where indicated, we think you should revise your future filings in response to these comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanations. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Form 10-KSB for the Fiscal Year Ended December 31, 2005
Description of Business
Vineyard
1. We note your response to our prior comment one. Please confirm that you will disclose the significant terms of this purchase agreement in future filings.
Notes to Financial Statements
Mr. James W. Bernau Willamette Valley Vineyards, Inc. January 9, 2007 Page 2
1. Summary of Operations, Basis of Pres entation and Significant Accounting Policies
Cost of Goods Sold
2. We note your response to our prior comment two. Please disclose the methodology you use to allocate fixed costs to inventory in future filings.
* * * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Scott Ruggiero at (202) 551-3331 or Andrew Blume at (202) 551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3716 with any other questions.
Sincerely,
William Choi
Branch Chief
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404
DIVISION OF
CORPORATION FINANCE
Mail Stop 3561
January 9, 2007
Mr. James W. Bernau
President
Willamette Valley Vineyards, Inc.
8800 Enchanted Way, SE
Turner, OR 97392
Re: Willamette Valley Vineyards, Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2005
Filed March 31, 2006
Form 10-Q for the Quarterly Period Ended September 30, 2006
Filed November 14, 2006
File No. 0-21522
Dear Mr. Bernau:
We have reviewed your response letter dated December 15, 2006 and have the following
comments. Where indicated, we think you should revise your future filings in response to these
comments. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanations. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Form 10-KSB for the Fiscal Year Ended December 31, 2005
Description of Business
Vineyard
1. We note your response to our prior comment one. Please confirm that you will disclose the significant terms of this purchase agreement in future filings.
Notes to Financial Statements
Mr. James W. Bernau
Willamette Valley Vineyards, Inc.
January 9, 2007 Page 2
1. Summary of Operations, Basis of Pres entation and Significant Accounting Policies
Cost of Goods Sold
2. We note your response to our prior comment two. Please disclose the methodology you use to allocate fixed costs to inventory in future filings.
* * * * *
Please respond to these comments within 10 business days or tell us when you will
provide us with a response. Please furnish a cover letter that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Scott Ruggiero at (202) 551-3331 or Andrew Blume at (202) 551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3716 with any other questions.
Sincerely,
William Choi
Branch Chief