SEC Comment Letter for ROCKY BRANDS, INC. (RCKY) (CIK 0000895456) (RCKY) — Jul 26, 2005
ROCKY BRANDS, INC. (RCKY) (CIK 0000895456)
Date: July 26, 2005 · CIK: 0000895456 · Accession: 0000000000-05-038144
AI Filing Summary & Sentiment
Referenced dates: July 15, 2005, June 15, 2005
Letter
Mail Stop 3561 July 22, 2005 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 July 15, 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 two of our letter dated June 15, 2005. Please provide to us three years of revenue information for each operating segment you have identified. Also, provide three years of profit (loss), and asset information for each operating segment identified. See paragraph 18 of SFAS no. 131.
```````````````````````````````````````````````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 3561 July 22, 2005 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 July 15, 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 two of our letter dated June 15, 2005. Please provide to us three years of revenue information for each operating segment you have identified. Also, provide three years of profit (loss), and asset information for each operating segment identified. See paragraph 18 of SFAS no. 131. ```````````````````````````````````````````````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 ?? ?? ?? ?? Mr. James McDonald Rocky Shoes and Boots, Inc. July 22, 2005 Page 2 </TEXT> </DOCUMENT>