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SEC Company Response from PECO II INC (CIK 0000845072) — Jun 13, 2005

PECO II INC (CIK 0000845072)
Date: June 13, 2005 · CIK: 0000845072 · Accession: 0001193125-05-124308

AI Filing Summary & Sentiment

Date
June 9, 2005
Author
/s/ Sandra A. Frankhouse
Form
CORRESP
Company
PECO II INC (CIK 0000845072)

Letter

Via Edgar and FedEx Division of Corporation Finance Securities and Exchange Commission Peco II, Inc. Form 8-K Item 4.01 Filed June 3, 2005 File No. 0-31283

Dear Ms. Armelin,

We have received your comments to our Form 8-K Item 4.01, filed by Peco II, Inc. (the “Company”) on June 3, 2005, File No. 0-31283, set forth in your letter dated as of June 6, 2005. Our responses to your comments in this letter are numbered to correspond to the numbers contained in your June 6, 2005 letter. We respectfully respond to the comments as follows:

1. When we engage a new accountant, the company will report the engagement in a new Form 8-K and comply with the requirements of Regulation S-K Item 304 (a)(2). This will name the newly engaged accountant and indicate the date of the engagement. There has been no consulting with any independent accountants regarding application of accounting principles specific to a transaction, no discussions regarding types of opinions rendered, and no oral advice provided by a new accountant so there will be no disclosure regarding these items.

Should the situation change prior to the engagement, and consultations do occur, we ensure the information will be disclosed regarding consulting up through the date of engagement.

The company acknowledges that:

•

the company is responsible for the adequacy and accuracy of the disclosure in their filings with the Commission (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 Filings: 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.

If you have any questions regarding any of the foregoing, please contact Sandra A. Frankhouse, Peco II, Inc., at (419) 468-7600 ext 1223.

Thank you for your assistance.

Sincerely,
/s/ Sandra A. Frankhouse

Show Raw Text
CORRESP
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SEC Response Letter

 PECO II, Inc.

 1376 State Route 598

 Galion, OH 44833

 (419) 468-7600

 Fax (419) 468-9164

 www.peco2.com

 June 9, 2005

 Via Edgar and FedEx

 Patricia A Armelin

 Staff Accountant

 Division of Corporation Finance

 Securities and Exchange Commission

 450 Fifth Street, N.W.

 Washington, D.C. 20549

Re:

Peco II, Inc.

Form 8-K Item 4.01

Filed June 3, 2005

File No. 0-31283

 Dear Ms. Armelin,

 We have received your comments to our Form 8-K Item 4.01, filed by Peco II, Inc. (the
“Company”) on June 3, 2005, File No. 0-31283, set forth in your letter dated as of June 6, 2005. Our responses to your comments in this letter are numbered to correspond to the numbers contained in your June 6, 2005 letter. We respectfully
respond to the comments as follows:

1.
When we engage a new accountant, the company will report the engagement in a new Form 8-K and comply with the requirements of Regulation S-K Item 304 (a)(2). This will name the
newly engaged accountant and indicate the date of the engagement. There has been no consulting with any independent accountants regarding application of accounting principles specific to a transaction, no discussions regarding types of opinions
rendered, and no oral advice provided by a new accountant so there will be no disclosure regarding these items.

 Should the situation change prior to the engagement, and consultations do occur, we ensure the information will be disclosed regarding consulting up
through the date of engagement.

 The company acknowledges that:

•

the company is responsible for the adequacy and accuracy of the disclosure in their filings with the Commission (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
Filings: 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.

 If you have any questions regarding any of the foregoing, please
contact Sandra A. Frankhouse, Peco II, Inc., at (419) 468-7600 ext 1223.

 Thank
you for your assistance.

 Sincerely,

 /s/ Sandra A. Frankhouse

Sandra A. Frankhouse

CFO/ Treasurer