SEC Comment Letter for TRINITY BIOTECH PLC (TRIB) (CIK 0000888721) (TRIB) — Sep 21, 2006
TRINITY BIOTECH PLC (TRIB) (CIK 0000888721)
Date: Sept. 21, 2006 · CIK: 0000888721 · Accession: 0000000000-06-045729
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-22320
Letter
Via Facsimile and U.S. Mail Mail Stop 6010 September 21, 2006 Rory Nealon Director/Chief Financial Officer Trinity Biotech plc IDA Business Park Bray, CO. Wicklow, Ireland
Re: Trinity Biotech plc Form 20-F for Fiscal Year Ended December 31, 2005 Filed March 31, 2006 File No. 000-22320
Dear Mr. Nealon:
We have reviewed your filing and have the following comments. We have limited our review to only your financial stat ements and related disclosures and do not intend to expand our review to other portions of your documents. In our comments, we ask you to provide us with information so we may better understa nd your disclosure. Please be as detailed as nece ssary in your explanation. Afte r reviewing this information, we may raise additional comments.
Please understand that the purpose of our re view 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Item 5. Operating And Financial Review And Prospects, page 18
Critical Accounting Policies And Estimates, page 19 1. Consistent with Section V. of Financia l Reporting Release 72, please provide us the following information, in disclosure-type format, about each of the estimates you have discussed:
Rory Nealon Trinity Biotech plc September 21, 2006 Page 2 • The amount of change in each estim ate and its effect on the revenue recognized and/or profit before tax for each period presented or, that changes in the estimate have not been material; and,
• The effect of a reasonably likely change in each estimate as of the latest balance sheet date on revenue and/or profit before tax.
Liquidity And Capital Resources, page 27
Working Capital, page 28 2. Please provide us, in disclosure type format, a more prospective and robust discussion of known demands, commitments, trends and uncertainties on your liquidity and the expected mix and cost of your capital resources. Explain fluctuations in cash flows from operations as reported on the cash flow statement.
* * * *
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provide the requested information. Detailed letters gr eatly facilitate our review. You should furnish the letter to us via EDGAR under the form type label CORRESP.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing include all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our co mments, please provide, in your letter, a statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
Rory Nealon Trinity Biotech plc September 21, 2006 Page 3 In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
You may contact James Pe klenk, Staff Accountant, at (202) 551-3661, or Lisa Vanjoske, Assistant Chief Accountant, at ( 202) 551-3614 if you have questions regarding the comments. In this regard, do not he sitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant
Show Raw Text
Via Facsimile and U.S. Mail
Mail Stop 6010
September 21, 2006
Rory Nealon
Director/Chief Financial Officer
Trinity Biotech plc
IDA Business Park
Bray, CO. Wicklow, Ireland
Re: Trinity Biotech plc
Form 20-F for Fiscal Year Ended December 31, 2005
Filed March 31, 2006
File No. 000-22320
Dear Mr. Nealon:
We have reviewed your filing and have the following comments. We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to other portions of your documents. In our comments, we
ask you to provide us with information so we may better understa nd your disclosure.
Please be as detailed as nece ssary in your explanation. Afte r reviewing this information,
we may raise additional comments.
Please understand that the purpose of our re view 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 on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Item 5. Operating And Financial Review And Prospects, page 18
Critical Accounting Policies And Estimates, page 19
1. Consistent with Section V. of Financia l Reporting Release 72, please provide us
the following information, in disclosure-type format, about each of the estimates you have discussed:
Rory Nealon
Trinity Biotech plc
September 21, 2006 Page 2
• The amount of change in each estim ate and its effect on the revenue
recognized and/or profit before tax for each period presented or, that changes
in the estimate have not been material; and,
• The effect of a reasonably likely change in each estimate as of the latest
balance sheet date on revenue and/or profit before tax.
Liquidity And Capital Resources, page 27
Working Capital, page 28
2. Please provide us, in disclosure type format, a more prospective and robust
discussion of known demands, commitments, trends and uncertainties on your
liquidity and the expected mix and cost of your capital resources. Explain
fluctuations in cash flows from operations as reported on the cash flow statement.
* * * *
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please furnish a letter that keys your responses to our comments and provide the requested information. Detailed letters gr eatly facilitate our
review. You should furnish the letter to us via EDGAR under the form type label
CORRESP.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing include all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
Rory Nealon
Trinity Biotech plc
September 21, 2006 Page 3
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact James Pe klenk, Staff Accountant, at (202) 551-3661, or Lisa
Vanjoske, Assistant Chief Accountant, at ( 202) 551-3614 if you have questions regarding
the comments. In this regard, do not he sitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant