SEC Comment Letter for MIND TECHNOLOGY, INC (MIND) (CIK 0000926423) (MIND) — Feb 18, 2011
MIND TECHNOLOGY, INC (MIND) (CIK 0000926423)
Date: Feb. 18, 2011 · CIK: 0000926423 · Accession: 0000000000-11-010819
AI Filing Summary & Sentiment
Referenced dates: February 8, 2011
Letter
February 18, 2011 Mitcham Industries, Inc. Robert P. Capps, Executive Vice Presiden t – Finance and Chief Financial Officer 8141 SH 75 South P.O. Box 1175 Huntsville, TX 33742
Re: Mitcham Industries, Inc. Form 10-K for the year ended January 31, 2010 filed April 9, 2010 Form 10-Q for the quarter ended October 31, 2010 filed December 8, 2010 File No. 0-25142
Dear Mr. Capps: We have reviewed your response to our letter dated February 8, 2011 and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10-K for the year ended January 31, 2010
Critical Accounting Policies
Goodwill and Other Intangible Assets, page 34
We have read your response to prior comment one of our letter dated February 8, 2011. Please clarify how you have determined that Seamap UK and Seamap Singa pore are not operating segments as defined in ASC 280-10-50-1. In this re gard, please specifically confirm, if true, that your chief operating decision maker does not rece ive and regularly review each subsidiary’s operating results to make decisions about resources to be allocated to the subsidiary and assess its performance.
Mr. Robert P. Capps Mitcham Industries, Inc. February 18, 2011 Page 2
You may contact Mindy Hooker at (202) 551-3732, Jeanne Baker at (202) 551-3691 or me at (202) 551-3768 with any questions. Sincerely,
John Cash Branch Chief
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February 18, 2011 Mitcham Industries, Inc. Robert P. Capps, Executive Vice Presiden t – Finance and Chief Financial Officer 8141 SH 75 South P.O. Box 1175 Huntsville, TX 33742 Re: Mitcham Industries, Inc. Form 10-K for the year ended January 31, 2010 filed April 9, 2010 Form 10-Q for the quarter ended October 31, 2010 filed December 8, 2010 File No. 0-25142 Dear Mr. Capps: We have reviewed your response to our letter dated February 8, 2011 and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10-K for the year ended January 31, 2010 Critical Accounting Policies Goodwill and Other Intangible Assets, page 34 We have read your response to prior comment one of our letter dated February 8, 2011. Please clarify how you have determined that Seamap UK and Seamap Singa pore are not operating segments as defined in ASC 280-10-50-1. In this re gard, please specifically confirm, if true, that your chief operating decision maker does not rece ive and regularly review each subsidiary’s operating results to make decisions about resources to be allocated to the subsidiary and assess its performance. Mr. Robert P. Capps Mitcham Industries, Inc. February 18, 2011 Page 2 You may contact Mindy Hooker at (202) 551-3732, Jeanne Baker at (202) 551-3691 or me at (202) 551-3768 with any questions. Sincerely, John Cash Branch Chief