SEC Comment Letter for TRINITY BIOTECH PLC (TRIB) (CIK 0000888721) (TRIB) — Nov 28, 2006
TRINITY BIOTECH PLC (TRIB) (CIK 0000888721)
Date: Nov. 28, 2006 · CIK: 0000888721 · Accession: 0000000000-06-058212
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-22320
Letter
Via Facsimile and U.S. Mail Mail Stop 6010 November 28, 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 October 6, 2006 response to our September 21, 2006 letter and have the following additional comm ent. In our comment, we ask you to provide us with information so we may better understa nd your disclosure. Please be as detailed as necessary in your explanation. After 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 filings. We look forward to working with you in these respects. We welcome any questions you may have about our comment 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 Liquidity And Capital Resources, page 27 Working Capital, page 28 1. Your response to our comment two merely states that accounts receivable at December 31, 2005 increased because sales increased. However, it appears that accounts receivable increased at a rate grea ter than the increase in sales. Using fourth quarter sales we computed days’ sa les in trade receivables as 44 days at December 31, 2004 and 57 days at December 31, 2005. Please explain this increase.
* * * *
Rory Nealon Trinity Biotech plc November 28, 2006 Page 2
Please respond to this comment 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 comment and provide the request ed information. Detailed le tters greatly facilitate our review. You should furnish the letter to us via EDGAR under the form type label CORRESP.
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 comment. 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
November 28, 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 October 6, 2006 response to our September 21, 2006
letter and have the following additional comm ent. In our comment, we ask you to provide
us with information so we may better understa nd your disclosure. Please be as detailed
as necessary in your explanation. After 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 filings. We look forward to working with you in these respects. We
welcome any questions you may have about our comment 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
Liquidity And Capital Resources, page 27
Working Capital, page 28
1. Your response to our comment two merely states that accounts receivable at December 31, 2005 increased because sales increased. However, it appears that accounts receivable increased at a rate grea ter than the increase in sales. Using
fourth quarter sales we computed days’ sa les in trade receivables as 44 days at
December 31, 2004 and 57 days at December 31, 2005. Please explain this increase.
* * * *
Rory Nealon
Trinity Biotech plc
November 28, 2006 Page 2
Please respond to this comment 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
comment and provide the request ed information. Detailed le tters greatly facilitate our
review. You should furnish the letter to us via EDGAR under the form type label
CORRESP.
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 comment. In this regard, do not he sitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant