SEC Comment Letter for STANDARD DIVERSIFIED INC. (CIK 0000911649) — Nov 17, 2005
STANDARD DIVERSIFIED INC. (CIK 0000911649)
Date: Nov. 17, 2005 · CIK: 0000911649 · Accession: 0000000000-05-058266
AI Filing Summary & Sentiment
File numbers found in text: 000-22400
Referenced dates: November 15, 2005
Letter
Mail Stop 7010 November 17, 2005 Mr. Anthony J. Simonetta Strategic Diagnostics Inc. 111 Pencader Drive Newark, Deleware 19702
RE: Strategic Diagnostics Inc. Form 10-K for the year ended December 31, 2004 Filed March 30, 2005 File No. 000-22400
Dear Mr. Simonetta:
We have reviewed your response letter dated November 15, and have the following additional comments. After reviewing this information, we may or may not raise additional comments.
FORM 10-K FOR THE PERIOD ENDED DECEMBER 31, 2004 1. We note that you anticipate recording the costs to produce a custom antibody as inventory at the lower of cost or market. Please tell us what you define as market and specifically how and when you plan to assess the custom antibody costs for impairment. 2. We understand from your previous response letters that customers can request additional antibodies using the same animals from their initial order. Please tell us what consideration you have given to this situation as it relates to your proposed accounting for the custom antibody costs. In particular, address the following. * Tell us how the timing of a customer request for additional antibodies affects your proposed policy. Address how and when a customer makes such requests. If the request is made prior to the delivery of the initial order, address how you will allocate costs between the initial order and subsequent orders. If the request is made subsequent to the delivery of the initial order, tell us how you will reflect appropriate gross margins on the subsequent antibody deliveries as we assume that, in accordance with your proposed accounting for the costs to produce a custom antibody, all such costs would have been expensed upon shipment of the original order. In addition, if you are recognizing fees from housing an animal and waiting on a decision from a customer regarding subsequent antibody orders, tell us how you will treat the accumulated costs related to the initial antibody production. * Please ensure that your response contemplates your business practices utilized in each period presented in your fiscal 2004 Form 10-K through the current period.
3. Tell us the typical timeframe between the completion of your work to produce the custom antibodies and shipment to your customers.
* * * *
As appropriate, 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 provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comments.
If you have any questions regarding these comments, please direct them to Patricia Armelin, Staff Accountant, at (202) 551-3747, Jeanne Baker at (202) 551-3691 or, in their absence, to the undersigned at (202) 551-3768.
Sincerely,
John Cash
Accounting Branch Chief
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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Mail Stop 7010
November 17, 2005
Mr. Anthony J. Simonetta
Strategic Diagnostics Inc.
111 Pencader Drive
Newark, Deleware 19702
RE: Strategic Diagnostics Inc.
Form 10-K for the year ended December 31, 2004
Filed March 30, 2005
File No. 000-22400
Dear Mr. Simonetta:
We have reviewed your response letter dated November 15,
2005
and have the following additional comments. After reviewing this
information, we may or may not raise additional comments.
FORM 10-K FOR THE PERIOD ENDED DECEMBER 31, 2004
1. We note that you anticipate recording the costs to produce a
custom
antibody as inventory at the lower of cost or market. Please tell
us
what you define as market and specifically how and when you plan
to
assess the custom antibody costs for impairment.
2. We understand from your previous response letters that
customers
can request additional antibodies using the same animals from
their
initial order. Please tell us what consideration you have given
to
this situation as it relates to your proposed accounting for the
custom antibody costs. In particular, address the following.
* Tell us how the timing of a customer request for additional
antibodies affects your proposed policy. Address how and when a
customer makes such requests. If the request is made prior to the
delivery of the initial order, address how you will allocate costs
between the initial order and subsequent orders. If the request
is
made subsequent to the delivery of the initial order, tell us how
you
will reflect appropriate gross margins on the subsequent antibody
deliveries as we assume that, in accordance with your proposed
accounting for the costs to produce a custom antibody, all such
costs
would have been expensed upon shipment of the original order. In
addition, if you are recognizing fees from housing an animal and
waiting on a decision from a customer regarding subsequent
antibody
orders, tell us how you will treat the accumulated costs related
to
the initial antibody production.
* Please ensure that your response contemplates your business
practices utilized in each period presented in your fiscal 2004
Form
10-K through the current period.
3. Tell us the typical timeframe between the completion of your
work
to produce the custom antibodies and shipment to your customers.
* * * *
As appropriate, 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
provides any requested supplemental information. Detailed
response
letters greatly facilitate our review. Please file your response
letter on EDGAR. Please understand that we may have additional
comments after reviewing your response to our comments.
If you have any questions regarding these comments, please
direct
them to Patricia Armelin, Staff Accountant, at (202) 551-3747,
Jeanne
Baker at (202) 551-3691 or, in their absence, to the undersigned
at
(202) 551-3768.
Sincerely,
John Cash
Accounting Branch Chief
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Mr. Anthony J. Simonetta
Strategic Diagnostics Inc.
November 17, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
</TEXT>
</DOCUMENT>