SEC Comment Letter for MIND TECHNOLOGY, INC (MIND) (CIK 0000926423) (MIND) — May 1, 2006
MIND TECHNOLOGY, INC (MIND) (CIK 0000926423)
Date: May 1, 2006 · CIK: 0000926423 · Accession: 0000000000-06-020256
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE April 25, 2006 Mr. Michael A. Pugh Chief Financial Officer, Mitcham Industries, Inc. 8141 SH 75 South P.O. Box 1175 Huntsville, TX 77342
Re: Mitcham Industries, Inc. Form 10-K for the fiscal year ended January 31, 2005 File No. 0-25142
Dear Mr. Pugh:
We have reviewed your response to our lette r dated April 6, 2006 and have the following comments. We ask that you respond by May 9, 2006.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requir ements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspe ct of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Statement of Consolidated Cash Flows Lease pool equipment and new equipment sales
1. We have reviewed the comparison of summarized annual consolidated statements of cash flows, original vs. restated as well as the a dditional information sent to us via facsimile on April 25, 2006. As of the date of this le tter, we are awaiting further information regarding your 2004 and 2005 restated amounts. In light of your request that we assist you in meeting your filing timetable for your 2006 Form 10-K we will separately address any additional concerns or comments we may have on your 2004 and 2005 restated amounts once you have provided us with the requested additional information.
Mr. Michael Pugh Mitcham Industries, Inc. April 25, 2006 Page 2 Note 1 – Organization and Summary of Signifi cant Accounting Policies – Seismic Equipment Lease Pool, page F-8
2. Based on your response to prior comment three we have the following additional comments:
• We note your policy regarding the removal of a ssets that are fully depreciated from your books is, “if an asset is fully depreciated and is still expected to generate revenue, then the asset will remain on [your] books. However, if a fully depreciated asset is not expected to have any revenue generating capac ity, then [you] will re move the asset from [your] books.” We also note that you are “unable to determine whether a particular asset is generating revenues.” We assume theref ore that your policy regarding the removal of assets that are fully depreciated from your books is done at the “major category” of assets level rather than at an individual asset level. Please ensure your stated policy in future filings is clear. Also, please expand your policy to discuss when and how you assess your lease pool assets to determine whether your fully de preciated assets are still generating revenue.
• We note that at January 31, 2005 you had $24.3 million of assets on your books which were fully depreciated. We assume that you will revise your January 31, 2005 balance sheet to comply with your stated policy rega rding the removal of assets that are fully depreciated but not expected to have any revenue generating capacity.
• Expand Management’s Discussion and Analysis to quantify the amount of gross assets which were fully depreciated but still generating revenue at January 31, 2005 and January 31, 2006. We believe that this disclosure will enhance an investors understanding of your results of operations as we ll as your liquidity.
• We note that you have recorded an impairment charge relating to your lease pool in fiscal 2006. In your disclosure regarding this impair ment, please ensure that you identify the nature of the asset impaired (the major categor y of assets impaired) and you include all of the disclosures required by paragraph 26 of SFAS 144.
Please respond to these comments within 10 business days, or tell us when you will provide us with a response. Pl ease provide us with a supplementa l response letter that keys your responses to our comments and provides any re quested supplemental information. Detailed letters greatly facilitate our review. Please file your supplemental response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments.
Mr. Michael Pugh Mitcham Industries, Inc. April 25, 2006 Page 3 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. Since the company and its management are in possession of a ll facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
If you have any questions regarding these comments, please direct them to Mindy Hooker, Staff Accountant, at (202) 551-3732, Jeanne Baker, A ssistant Chief Accountant, at (202) 551-3691 or to the unde rsigned at (202) 551-3768.
Sincerely,
John Cash
Branch Chief
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
April 25, 2006
Mr. Michael A. Pugh
Chief Financial Officer, Mitcham Industries, Inc.
8141 SH 75 South
P.O. Box 1175
Huntsville, TX 77342
Re: Mitcham Industries, Inc.
Form 10-K for the fiscal year ended January 31, 2005
File No. 0-25142
Dear Mr. Pugh:
We have reviewed your response to our lette r dated April 6, 2006 and have the following
comments. We ask that you respond by May 9, 2006.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing. We look forward to working with you in these respects. We welcome any questions
you may have about our comments or on any other aspe ct of our review. Feel free to call us at
the telephone numbers listed at the end of this letter.
Statement of Consolidated Cash Flows
Lease pool equipment and new equipment sales
1. We have reviewed the comparison of summarized annual consolidated statements of cash
flows, original vs. restated as well as the a dditional information sent to us via facsimile
on April 25, 2006. As of the date of this le tter, we are awaiting further information
regarding your 2004 and 2005 restated amounts. In light of your request that we assist
you in meeting your filing timetable for your 2006 Form 10-K we will separately address
any additional concerns or comments we may have on your 2004 and 2005 restated
amounts once you have provided us with the requested additional information.
Mr. Michael Pugh
Mitcham Industries, Inc.
April 25, 2006
Page 2
Note 1 – Organization and Summary of Signifi cant Accounting Policies – Seismic Equipment
Lease Pool, page F-8
2. Based on your response to prior comment three we have the following additional
comments:
• We note your policy regarding the removal of a ssets that are fully depreciated from your
books is, “if an asset is fully depreciated and is still expected to generate revenue, then
the asset will remain on [your] books. However, if a fully depreciated asset is not expected to have any revenue generating capac ity, then [you] will re move the asset from
[your] books.” We also note that you are “unable to determine whether a particular asset is generating revenues.” We assume theref ore that your policy regarding the removal of
assets that are fully depreciated from your books is done at the “major category” of assets
level rather than at an individual asset level. Please ensure your stated policy in future
filings is clear. Also, please expand your policy to discuss when and how you assess
your lease pool assets to determine whether your fully de preciated assets are still
generating revenue.
• We note that at January 31, 2005 you had $24.3 million of assets on your books which
were fully depreciated. We assume that you will revise your January 31, 2005 balance
sheet to comply with your stated policy rega rding the removal of assets that are fully
depreciated but not expected to have any revenue generating capacity.
• Expand Management’s Discussion and Analysis to quantify the amount of gross assets
which were fully depreciated but still generating revenue at January 31, 2005 and January
31, 2006. We believe that this disclosure will enhance an investors understanding of your results of operations as we ll as your liquidity.
• We note that you have recorded an impairment charge relating to your lease pool in fiscal 2006. In your disclosure regarding this impair ment, please ensure that you identify the
nature of the asset impaired (the major categor y of assets impaired) and you include all of
the disclosures required by paragraph 26 of SFAS 144.
Please respond to these comments within 10 business days, or tell us when you will
provide us with a response. Pl ease provide us with a supplementa l response letter that keys your
responses to our comments and provides any re quested supplemental information. Detailed
letters greatly facilitate our review. Please file your supplemental response on EDGAR as a
correspondence file. Please understand that we may have additional comments after reviewing
your responses to our comments.
Mr. Michael Pugh
Mitcham Industries, Inc.
April 25, 2006
Page 3
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filings reviewed by the staff to be certain that they have provided all information investors
require. Since the company and its management are in possession of a ll facts relating to a
company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they
have made.
If you have any questions regarding these comments, please direct them to Mindy
Hooker, Staff Accountant, at (202) 551-3732, Jeanne Baker, A ssistant Chief Accountant, at
(202) 551-3691 or to the unde rsigned at (202) 551-3768.
Sincerely,
John Cash
Branch Chief