SEC Comment Letter for LAYNE CHRISTENSEN CO (CIK 0000888504) — Nov 28, 2005
LAYNE CHRISTENSEN CO (CIK 0000888504)
Date: Nov. 28, 2005 · CIK: 0000888504 · Accession: 0000000000-05-059581
AI Filing Summary & Sentiment
File numbers found in text: 000-20578
Letter
Mail Stop 7010 November 10, 2005 By U.S. Mail and Facsimile Mr. Jerry W. Fanska Vice President - Finance and Treasurer Layne Christensen Company 1900 Shawnee Mission Parkway Mission Woods, Kansas 66205
Re: Layne Christensen Company Form 10-K/A for the Fiscal Year Ended January 31, 2005 Forms 10-Q/A for the Fiscal Quarters Ended April 30, 2005 and July 31, 2005 File No. 000-20578
Dear Mr. Fanska:
We have reviewed your amended Exchange Act filings, filed on October 31, 2005, and have the following additional comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. After reviewing this information, we may or may not raise additional comments.
Exhibit 31 - Section 302 Certifications
1. We note your amendments to your Form 10-K for the fiscal year ended January 31, 2005 and Forms 10-Q for the fiscal quarters ended April 30, 2005 and July 31, 2005. Since the Section 302 certifications relate to the entire Form 10-K or Form 10-Q, an amendment to revise these certifications should include the entire filing. In this regard, please re-file your Form 10-K/A and Forms 10-Q/A for the aforementioned periods in their entirety. For guidance, you may refer to Question 17 of the Division of Corporation Finance: Sarbanes- Oxley Act of 2002 FAQ`s found on the Commission`s website at www.sec.gov.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please provide us with a supplemental response letter that keys your responses to our comments. Detailed cover letters greatly facilitate our review. Please file your supplemental response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, you may contact Dale Welcome, Staff Accountant, at (202) 551-3865, Nathan Cheney, Assistant Chief Accountant, at (202) 551-3714 or, in their absence, to the undersigned at (202) 551-3768.
Sincerely,
John Cash
Accounting Branch Chief
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<FILENAME>filename1.txt
<TEXT>
Mail Stop 7010
November 10, 2005
By U.S. Mail and Facsimile
Mr. Jerry W. Fanska
Vice President - Finance and Treasurer
Layne Christensen Company
1900 Shawnee Mission Parkway
Mission Woods, Kansas 66205
Re: Layne Christensen Company
Form 10-K/A for the Fiscal Year Ended January 31, 2005
Forms 10-Q/A for the Fiscal Quarters Ended April 30, 2005 and
July 31, 2005
File No. 000-20578
Dear Mr. Fanska:
We have reviewed your amended Exchange Act filings, filed on
October 31, 2005, and have the following additional comment. If
you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary. After reviewing this
information, we may or may not raise additional comments.
Exhibit 31 - Section 302 Certifications
1. We note your amendments to your Form 10-K for the fiscal year
ended
January 31, 2005 and Forms 10-Q for the fiscal quarters ended
April
30, 2005 and July 31, 2005. Since the Section 302 certifications
relate to the entire Form 10-K or Form 10-Q, an amendment to
revise
these certifications should include the entire filing. In this
regard, please re-file your Form 10-K/A and Forms 10-Q/A for the
aforementioned periods in their entirety. For guidance, you may
refer
to Question 17 of the Division of Corporation Finance: Sarbanes-
Oxley
Act of 2002 FAQ`s found on the Commission`s website at
www.sec.gov.
* * * *
Please respond to these comments within 10 business days
or
tell us when you will provide us with a response. Please provide
us
with a supplemental response letter that keys your responses to
our
comments. Detailed cover letters greatly facilitate our review.
Please file your supplemental response on EDGAR as a
correspondence
file. Please understand that we may have additional comments
after
reviewing your responses to our comments.
If you have any questions regarding these comments, you
may
contact Dale Welcome, Staff Accountant, at (202) 551-3865, Nathan
Cheney, Assistant Chief Accountant, at (202) 551-3714 or, in their
absence, to the undersigned at (202) 551-3768.
Sincerely,
John Cash
Accounting Branch Chief
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Mr. Jerry W. Fanska
Layne Christensen Company
November 10, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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