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SEC Comment Letter for FOOD TECHNOLOGY SERVICE INC (CIK 0000868267) — Apr 27, 2005

FOOD TECHNOLOGY SERVICE INC (CIK 0000868267)
Date: April 27, 2005 · CIK: 0000868267 · Accession: 0000000000-05-020546

AI Filing Summary & Sentiment

File numbers found in text: 000-19047

Date
April 27, 2005
Author
Steven Jacobs
Form
UPLOAD
Company
FOOD TECHNOLOGY SERVICE INC (CIK 0000868267)

Letter

Mail Stop 0409 VIA U.S. MAIL AND FAX (863) 425-5526 Mr. Richard G. Hunter, Ph. D. Chief Executive Officer and Chief Financial Officer Food Technology Service, Inc. 502 Prairie Mine Road Mulberry, FL 33860

Re: Food Technology Service, Inc. Form 10-KSB for the year ended December 31, 2004 File No. 000-19047

Dear Mr. Hunter:

We have reviewed your April 22, 2005 response letter and have the following additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. 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.

1. We read your response to comment 2. Please further explain to us how your recognition of revenue at the time of processing meets the delivery and performance criteria in SAB 101, as amended by SAB 104. Do you retain any risk after the product is processed but prior to pick-up by or shipment to your customer?

2. In a supplemental response, please confirm to us that you will revise your disclosure in future filings in response to our prior comments 2 and 3.

* * * *

You may contact Josh Forgione, at (202) 824-5464, or me, at (202) 824-5222, if you have questions. Please respond to the comments included in this letter within ten business days or tell us when you will provide us with a response. Please file your response on EDGAR.

Sincerely,
Steven Jacobs
Accounting Branch Chief
??

Show Raw Text
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<TEXT>

April 27, 2005

Mail Stop 0409

VIA U.S. MAIL AND FAX (863) 425-5526

Mr. Richard G. Hunter, Ph. D.
Chief Executive Officer and
   Chief Financial Officer
Food Technology Service, Inc.
502 Prairie Mine Road
Mulberry,  FL  33860

Re:	Food Technology Service, Inc.
Form 10-KSB for the year ended December 31, 2004
File No. 000-19047

Dear Mr. Hunter:

      We have reviewed your April 22, 2005 response letter and
have
the following additional comments.  Please understand that the
purpose of our review process is to assist you in your compliance
with the applicable disclosure requirements and to enhance the
overall disclosure in your filing.  We look forward to working
with
you in these respects.  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.

1. We read your response to comment 2.  Please further explain to
us
how your recognition of revenue at the time of processing meets
the
delivery and performance criteria in SAB 101, as amended by SAB
104.
Do you retain any risk after the product is processed but prior to
pick-up by or shipment to your customer?

2. In a supplemental response, please confirm to us that you will
revise your disclosure in future filings in response to our prior
comments 2 and 3.

*  *  *  *

	You may contact Josh Forgione, at (202) 824-5464, or me, at
(202) 824-5222, if you have questions. Please respond to the
comments
included in this letter within ten business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

							Sincerely,

Steven Jacobs
Accounting Branch Chief
??

??

??

??

Food Technology Service, Inc.
April 27, 2005
Page 1

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