SEC Comment Letter for ROCKY BRANDS, INC. (RCKY) (CIK 0000895456) (RCKY) — Jul 5, 2005
ROCKY BRANDS, INC. (RCKY) (CIK 0000895456)
Date: July 5, 2005 · CIK: 0000895456 · Accession: 0000000000-05-033918
AI Filing Summary & Sentiment
Referenced dates: June 2, 2005, May 13, 2005
Letter
June 15, 2005 By Facsimile and U.S. Mail James McDonald Chief Financial Officer Rocky Shoes and Boots, Inc. 39 East Canal Street Nelsonville, OH 45764
RE: Rock Shoes and Boots, Inc. File No. 0-21026 Form 10-K for the year ended December 31, 2004 Form 10-Q for the quarter ended March 31, 2005
Dear Mr. McDonald:
We reviewed your responses to our prior comments on the above referenced filings as set forth in your letter dated June 2, 2005. Our review resulted in the following accounting comment.
Form 10-K for the Year Ended December 31, 2004
1. We note your response to comment 4 of our letter dated May 13, 2005. Please provide to us your analysis with respect to the income statement classification regarding your co-operative advertising programs. Please be specific regarding each program you have with every customer. See paragraph 9, and the examples included within appendix A of EITF Issue 01-9.
2. We note your response to comment 14 of our letter dated May 13, 2005. It appears that you are reviewing performance based on branded footwear, branded accessories, and military sales. Also, you are reviewing performance separately for sourced and manufactured footwear. Furthermore, you are assessing performance of these business activities separately against the prior year performance, and budget. Provide to us your analysis with respect to operating segments regarding these business activities. The fact that you review operating expenses in total should not preclude you from considering whether you have separate operating segments. Also, describe how your general ledger system is coded, for example, explain in detail if you maintain separate accounts to track operating expenses for the business activities mentioned above. See paragraph 10 of SFAS no. 131. We may have further comment.
```````````````````````````````````````````````As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR as a correspondence file. ` If you have any questions regarding this comment, please direct them to Robert Babula, Staff Accountant, at (202) 551-3339 or, in his absence, to the undersigned at (202) 551-3841. Any other questions regarding disclosures issues may be directed to H. Christopher Owings, Assistant Director at (202) 551-3725.
Sincerely,
Michael Moran, Esq.
Branch Chief
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>filename1.txt <TEXT> Mail Stop 3-8 June 15, 2005 By Facsimile and U.S. Mail James McDonald Chief Financial Officer Rocky Shoes and Boots, Inc. 39 East Canal Street Nelsonville, OH 45764 RE: Rock Shoes and Boots, Inc. File No. 0-21026 Form 10-K for the year ended December 31, 2004 Form 10-Q for the quarter ended March 31, 2005 Dear Mr. McDonald: We reviewed your responses to our prior comments on the above referenced filings as set forth in your letter dated June 2, 2005. Our review resulted in the following accounting comment. Form 10-K for the Year Ended December 31, 2004 1. We note your response to comment 4 of our letter dated May 13, 2005. Please provide to us your analysis with respect to the income statement classification regarding your co-operative advertising programs. Please be specific regarding each program you have with every customer. See paragraph 9, and the examples included within appendix A of EITF Issue 01-9. 2. We note your response to comment 14 of our letter dated May 13, 2005. It appears that you are reviewing performance based on branded footwear, branded accessories, and military sales. Also, you are reviewing performance separately for sourced and manufactured footwear. Furthermore, you are assessing performance of these business activities separately against the prior year performance, and budget. Provide to us your analysis with respect to operating segments regarding these business activities. The fact that you review operating expenses in total should not preclude you from considering whether you have separate operating segments. Also, describe how your general ledger system is coded, for example, explain in detail if you maintain separate accounts to track operating expenses for the business activities mentioned above. See paragraph 10 of SFAS no. 131. We may have further comment. ```````````````````````````````````````````````As appropriate, please respond to this comment within 10 business days or tell us when you will provide us with a response. Please provide us with a response letter that keys your response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR as a correspondence file. ` If you have any questions regarding this comment, please direct them to Robert Babula, Staff Accountant, at (202) 551-3339 or, in his absence, to the undersigned at (202) 551-3841. Any other questions regarding disclosures issues may be directed to H. Christopher Owings, Assistant Director at (202) 551-3725. Sincerely, Michael Moran, Esq. Branch Chief ?? ?? ?? ?? James McDonald Rocky Shoes and Boots, Inc. June 15, 2005 Page 2 </TEXT> </DOCUMENT>