SEC Comment Letter for STANDARD DIVERSIFIED INC. (CIK 0000911649) — Dec 20, 2005
STANDARD DIVERSIFIED INC. (CIK 0000911649)
Date: Dec. 20, 2005 · CIK: 0000911649 · Accession: 0000000000-05-063167
AI Filing Summary & Sentiment
File numbers found in text: 000-22400
Referenced dates: December 8, 2005
Letter
Mail Stop 7010 December 13, 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 December 8, 2005 and have the following additional comments.
FORM 10-K FOR THE PERIOD ENDED DECEMBER 31, 2004 1. We disagree with your quantitative assessment of materiality and believe that the financial statements included in your Form 10-K for the year ended December 31, 2004 and subsequent Form 10-Qs should be restated. We remind you that your restated financial statements must include all the disclosures required by APB 20. 2. We note that your quantitative analysis includes the impact of proposed 2004 audit adjustments that were not recorded because you concluded that the impact of those adjustments were immaterial. Please provide us with a revised quantitative analysis that excludes the impact of those adjustments. In addition, provide us with the detail of those unrecorded adjustments, including an analysis of how those adjustments were evaluated for materiality on an "as recorded" and "as restated" basis. 3. We have reviewed your proposed treatment regarding the evaluation of the custom antibody costs for impairment as well as the treatment of additional custom antibody orders. Your filings should be revised to include disclosure of these accounting policies. Please provide us with a draft of your proposed disclosures on a supplemental basis.
* * * *
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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<TEXT>
Mail Stop 7010
December 13, 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 December 8, 2005
and have the following additional comments.
FORM 10-K FOR THE PERIOD ENDED DECEMBER 31, 2004
1. We disagree with your quantitative assessment of materiality
and
believe that the financial statements included in your Form 10-K
for
the year ended December 31, 2004 and subsequent Form 10-Qs should
be
restated. We remind you that your restated financial statements
must
include all the disclosures required by APB 20.
2. We note that your quantitative analysis includes the impact of
proposed 2004 audit adjustments that were not recorded because you
concluded that the impact of those adjustments were immaterial.
Please provide us with a revised quantitative analysis that
excludes
the impact of those adjustments. In addition, provide us with the
detail of those unrecorded adjustments, including an analysis of
how
those adjustments were evaluated for materiality on an "as
recorded"
and "as restated" basis.
3. We have reviewed your proposed treatment regarding the
evaluation
of the custom antibody costs for impairment as well as the
treatment
of additional custom antibody orders. Your filings should be
revised
to include disclosure of these accounting policies. Please
provide
us with a draft of your proposed disclosures on a supplemental
basis.
* * * *
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.
December 13, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
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