SEC Comment Letter for MILESTONE SCIENTIFIC INC. (MLSS) (CIK 0000855683) (MLSS) — Dec 18, 2007
MILESTONE SCIENTIFIC INC. (MLSS) (CIK 0000855683)
Date: Dec. 18, 2007 · CIK: 0000855683 · Accession: 0000000000-07-061225
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Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 6010 December 18, 2007 Mr. Leonard Osser Chairman and Chief Executive Officer Milestone Scientific, Inc. 220 South Orange Avenue Livingston Corporate Park Livingston, New Jersey 07039 RE: Milestone Scientific, Inc. Form 10-KSB for the fiscal year ended December 31, 2006 Filed April 2, 2007 File No. 1-14053
Dear Mr. Osser: In connection with our financial statement only review of Milestone Scientific’s 2006 Form 10-KSB and subse quent Exchange Act filings, we have the following additional accounting comments. Form 10-QSB for the period ended September 30, 2007
Financial Statements, page 4
Note 1 - Summary of accounting policies, page 8
Revenue Recognition
1. Refer to prior comment 5 from our lett er dated October 12, 2007. We refer to your response and request you specifi cally identify where we can find your expanded discussion of revenue recogn ition. We see no revenue recognition
Leonard Osser Milestone Scientific, Inc. December 18, 2007 Page 2 policy disclosure in the footnotes to the fi nancial statements. Confirm your future filings will include the expanded re venue recognition policy disclosures previously requested.
2. To this regard, please make sure your future accounting policy disclosures indicate how you account for the STA market introduction sales incentive programs.
Management’s Discussion and Analysis, page 13
Results of Operations, page 16
3. Please tell us and disclose in future fili ngs why the cost of royalty expense has a credit balance.
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your response that keys your responses to our comments and provides any requested supplemental information. Detailed cover lett ers greatly facilitate our review. Please submit your cover letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Dennis Hult, Staff Accountant, at (202) 551-3618 or myself if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3603 with any other questions. In this regard, do not hesitate to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-3554.
S i n c e r e l y , J a y W e b b Reviewing Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 6010
December 18, 2007
Mr. Leonard Osser Chairman and Chief Executive Officer Milestone Scientific, Inc. 220 South Orange Avenue Livingston Corporate Park Livingston, New Jersey 07039 RE: Milestone Scientific, Inc.
Form 10-KSB for the fiscal year ended December 31, 2006 Filed April 2, 2007 File No. 1-14053
Dear Mr. Osser: In connection with our financial statement only review of Milestone
Scientific’s 2006 Form 10-KSB and subse quent Exchange Act filings, we have
the following additional accounting comments.
Form 10-QSB for the period ended September 30, 2007
Financial Statements, page 4
Note 1 - Summary of accounting policies, page 8
Revenue Recognition
1. Refer to prior comment 5 from our lett er dated October 12, 2007. We refer to
your response and request you specifi cally identify where we can find your
expanded discussion of revenue recogn ition. We see no revenue recognition
Leonard Osser
Milestone Scientific, Inc.
December 18, 2007 Page 2
policy disclosure in the footnotes to the fi nancial statements. Confirm your future
filings will include the expanded re venue recognition policy disclosures
previously requested.
2. To this regard, please make sure your future accounting policy disclosures
indicate how you account for the STA market introduction sales incentive
programs.
Management’s Discussion and Analysis, page 13
Results of Operations, page 16
3. Please tell us and disclose in future fili ngs why the cost of royalty expense has a
credit balance.
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Please furnish a cover letter with your
response that keys your responses to our comments and provides any requested
supplemental information. Detailed cover lett ers greatly facilitate our review. Please
submit your cover letter on EDGAR. Please understand that we may have additional
comments after reviewing your responses to our comments.
You may contact Dennis Hult, Staff Accountant, at (202) 551-3618 or myself if
you have questions regarding comments on the financial statements and related matters.
Please contact me at (202) 551-3603 with any other questions. In this regard, do not
hesitate to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-3554.
S i n c e r e l y , J a y W e b b Reviewing Accountant