SEC Comment Letter for ESCO TECHNOLOGIES INC (ESE) (CIK 0000866706) (ESE) — Apr 15, 2010
ESCO TECHNOLOGIES INC (ESE) (CIK 0000866706)
Date: April 15, 2010 · CIK: 0000866706 · Accession: 0000000000-10-020709
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 1, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549
DIVISION OF CORPORATION FINANCE
Mail Stop 3720 April 15, 2010 via U.S. Mail and fax at 314-213-7250
Mr. V.L. Richey, Jr. Chairman, President and Chief Executive Officer ESCO Technologies Inc. 9900A Clayton Road St. Louis, Missouri 63124-1186 RE: ESCO Technologies Inc. Form 10-K for the year ended September 30, 2009 Filed November 30, 2009 File No. 1-10596 Dear Mr. Richey: We have reviewed your response letter dated April 1, 2010, and have the following comment. Please respond to our comment within 10 business days or tell us by that time when you will provide us with a re sponse. If the comment requests revised disclosure in future filings, please confir m in writing that you intend to do so. We welcome any questions you may have about our comment or any other aspect of our review. Compensation Consultant and Market Checking, page 9 of the Proxy Statement
1. We note your response to comment seven in our letter date d March 4, 2010, and are unable to agree that the composite surv eys do not need to be disclosed. As previously stated, Item 402 of Regula tion S-K requires you to identify the component companies used for benchmar king purposes. As you are using these surveys for benchmarking purposes, you must identify each company included in the surveys by name, regardless of the size of the benchmarking list. Please confirm that you will identify all compan ies used for benchmarking purposes in future filings. * * * *
Mr. V.L. Richey, Jr. ESCO Technologies Inc. April 15, 2010 Page 2 of 2 Please furnish a letter that keys your re sponse to our comment and provides any requested information. Detailed letters greatl y facilitate our review . Please file your letter over EDGAR. Please understand that we may have additional comments after reviewing your response to our comment. Please contact Jay Knight, Staff Attorney, at (202) 551-3370 or me at (202) 551- 3350 with any questions. S i n c e r e l y , / s / K a t h l e e n K r e b s K a t h l e e n K r e b s S p e c i a l C o u n s e l
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3720
April 15, 2010
via U.S. Mail and fax at 314-213-7250
Mr. V.L. Richey, Jr. Chairman, President and Chief Executive Officer ESCO Technologies Inc.
9900A Clayton Road
St. Louis, Missouri 63124-1186
RE: ESCO Technologies Inc.
Form 10-K for the year ended September 30, 2009 Filed November 30, 2009 File No. 1-10596
Dear Mr. Richey:
We have reviewed your response letter dated April 1, 2010, and have the
following comment. Please respond to our comment within 10 business days or tell us by that time when you will provide us with a re sponse. If the comment requests revised
disclosure in future filings, please confir m in writing that you intend to do so. We
welcome any questions you may have about our comment or any other aspect of our review.
Compensation Consultant and Market Checking, page 9 of the Proxy Statement
1. We note your response to comment seven in our letter date d March 4, 2010, and
are unable to agree that the composite surv eys do not need to be disclosed. As
previously stated, Item 402 of Regula tion S-K requires you to identify the
component companies used for benchmar king purposes. As you are using these
surveys for benchmarking purposes, you must identify each company included in
the surveys by name, regardless of the size of the benchmarking list. Please
confirm that you will identify all compan ies used for benchmarking purposes in
future filings.
* * * *
Mr. V.L. Richey, Jr.
ESCO Technologies Inc. April 15, 2010 Page 2 of 2
Please furnish a letter that keys your re sponse to our comment and provides any
requested information. Detailed letters greatl y facilitate our review . Please file your
letter over EDGAR. Please understand that we may have additional comments after
reviewing your response to our comment.
Please contact Jay Knight, Staff Attorney, at (202) 551-3370 or me at (202) 551-
3350 with any questions. S i n c e r e l y , / s / K a t h l e e n K r e b s K a t h l e e n K r e b s S p e c i a l C o u n s e l