SEC Comment Letter for ZYNEX INC (ZYXI) (CIK 0000846475) (ZYXIQ) — Sep 8, 2009
ZYNEX INC (ZYXI) (CIK 0000846475)
Date: Sept. 8, 2009 · CIK: 0000846475 · Accession: 0000000000-09-049532
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3030 September 8, 2009 Via U.S. Mail and Facsimile Mr. Fritz G. Allison Chief Financial Officer Zynex, Inc. 8022 Southpark Circle, Suite 100 Littleton, CO 80120
Re: Zynex, Inc. Form 10-K for the Year Ended December 31, 2008 Filed April 15, 2009 File No. 033-26787-D
Dear Mr. Allison:
We have reviewed your response dated August 24, 2009 and have the following additional comments. Where i ndicated, we think you should revise your document in future filings in response to these comments. If you disa gree, we will consider y our explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Af ter reviewing this information, we may raise additional comments. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Fritz G. Allison Zynex, Inc. September 8, 2009 Page 2 Form 10-K as of December 31, 2008
Consolidated Financial Statements, page F-1
Note (2) Significant Accounting Policies, page F-7
Revenue Recognition and Allowances for Provi der Discounts and Uncollectibility, page F-7
1. We note your response to prior comment six in which you state that the use of an estimate of provider discounts applied against th e claims sent to the providers for goods and services performed duri ng the period is appropriate because there is sufficient historical information available within Zynex to serve as a basis for making the estimate. Please tell us in more detail what types of historical information are available, how it is utilized in making your estimates for provi der discounts and how the 2008 restatements impacted your ability to make estimates for provider discounts.
As appropriate, 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 comment 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 Lynn Dicker, Staff Accountant, at (202) 551-3616 or me at (202) 551- 3643 if you have questions regarding comments on th e financial statements and related matters. In this regard, do not hes itate to contact me or Martin James, Senior Assistant Chief Accountant, at (202) 551-3671 with any questions.
S i n c e r e l y ,
Kevin L. Vaughn A c c o u n t i n g B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3030
September 8, 2009
Via U.S. Mail and Facsimile
Mr. Fritz G. Allison Chief Financial Officer Zynex, Inc. 8022 Southpark Circle, Suite 100
Littleton, CO 80120
Re: Zynex, Inc.
Form 10-K for the Year Ended December 31, 2008
Filed April 15, 2009 File No. 033-26787-D
Dear Mr. Allison:
We have reviewed your response dated August 24, 2009 and have the following
additional comments. Where i ndicated, we think you should revise your document in future
filings in response to these comments. If you disa gree, we will consider y our explanation as to
why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary
in your explanation. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure. Af ter reviewing this information, we may raise
additional comments. We welcome any questions you may have about our comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. Fritz G. Allison
Zynex, Inc. September 8, 2009 Page 2
Form 10-K as of December 31, 2008
Consolidated Financial Statements, page F-1
Note (2) Significant Accounting Policies, page F-7
Revenue Recognition and Allowances for Provi der Discounts and Uncollectibility, page F-7
1. We note your response to prior comment six in which you state that the use of an
estimate of provider discounts applied against th e claims sent to the providers for goods
and services performed duri ng the period is appropriate because there is sufficient
historical information available within Zynex to serve as a basis for making the estimate.
Please tell us in more detail what types of historical information are available, how it is
utilized in making your estimates for provi der discounts and how the 2008 restatements
impacted your ability to make estimates for provider discounts.
As appropriate, 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 comment 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 Lynn Dicker, Staff Accountant, at (202) 551-3616 or me at (202) 551-
3643 if you have questions regarding comments on th e financial statements and related matters.
In this regard, do not hes itate to contact me or Martin James, Senior Assistant Chief Accountant,
at (202) 551-3671 with any questions.
S i n c e r e l y ,
Kevin L. Vaughn A c c o u n t i n g B r a n c h C h i e f