SEC Comment Letter for PROTECTION ONE INC (CIK 0000916230) — Aug 12, 2005
PROTECTION ONE INC (CIK 0000916230)
Date: Aug. 12, 2005 · CIK: 0000916230 · Accession: 0000000000-05-041788
AI Filing Summary & Sentiment
Referenced dates: April 29, 2005, May 27, 2005
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Mail Stop 3561
August 10, 2005
Via U.S. Mail and Fax (785) 856-9910
Mr. Darius G. Nevin
Executive Vice President and Chief Financial Officer
Protection One, Inc.
1035 N. 3rd Street
Suite 101
Lawrence, Kansas 66044
RE: Protection One, Inc.
Protection One Alarm Monitoring Inc.
Form 10-K for the fiscal year ended December 31, 2004
Form 10-K/A for the fiscal year ended December 31, 2004
Filed March 17, 2005 and March 24, 2005, respectively
Form 10-Q for the quarter ended March 31, 2005
Filed May 16, 2005
File Nos. 1-12181-01 and 1-12181, respectively
Dear Mr. Nevin:
We have reviewed your supplemental response letter dated May
27, 2005 well as your filings and have the following comments. As
noted in our comment letter dated April 29, 2005, 2005, we have
limited our review to your financial statements and related
disclosures and do not intend to expand our review to other
portions
of your documents.
Form 10-K/A for the year ended December 31, 2004
Notes to Consolidated Financial Statements
2, Summary of Significant Accounting Policies
(b) Revenue Recognition, page 9
1. We note your response to our prior comment 9 and your statement
that in an arrangement where the Company retains title to the
system,
you believe that there is "only one unit of accounting since there
is
not a sale of the system." Tell us your consideration of EITF 01-8
regarding whether your arrangements contain a lease of the
security
system.
2. Your response to prior comment 9 did not specifically address
your
deferral of revenues and direct costs relative to when you price
the
system lower than you otherwise would because of an accompanying
service agreement. Provide us with more details of what you mean
by
this statement and cite your basis in the accounting literature.
Form 10-Q for the quarterly period ended March 31, 2005
Notes to Condensed Consolidated Financial Statements
1. Basis of Consolidation and Interim Financial Information, page
7
3. We note the reduction of deferred customer acquisition costs
and
revenues "which have been subsumed into the estimated fair market
value adjustment for customer accounts." Tell us what the
referenced
statement means and why you believe this accounting treatment is
appropriate. Also, tell us the underlying assumptions used to
estimate fair value of the deferred customer acquisition costs.
* * * *
Please file your response to these comments within 10 business
days
via EDGAR or tell us when you will provide us with a response.
You
may contact Kathryn Jacobson, Staff Accountant, at (202) 551-3365
or
Kyle Moffatt, Branch Chief Accountant, at (202) 551-3836 if you
have
questions regarding comments on the financial statements and
related
matters. Please contact me at (202) 551-3810 with any other
questions.
Sincerely,
Larry Spirgel
Assistant Director
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Mr. Darius G. Nevin
Protection One Inc.
Protection One Alarm Monitoring Inc.
August 10, 2005
Page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
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