SEC Comment Letter for MIND TECHNOLOGY, INC (MIND) (CIK 0000926423) (MIND) — May 10, 2016
MIND TECHNOLOGY, INC (MIND) (CIK 0000926423)
Date: May 10, 2016 · CIK: 0000926423 · Accession: 0000000000-16-075690
AI Filing Summary & Sentiment
Letter
May 10 , 201 6 Mail Stop 4631 Via E -Mail Robert P. Capps Co-Chief Executive Officer and Chief Financial Officer Mitcham Industries, Inc. 8141 SH 75 South P.O. Box 1175 Huntsville, TX 77342
Re: Mitcham Industries, Inc. Amendment No. 2 to Registration Statement on Form S -1 Filed April 22, 2016 File No. 333 -208177
Dear Mr. Capps :
We have reviewed your amended registration statement and have the following comment . Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in y our response.
After reviewing any amendment to your registration statement and the information you provide in response to this comment , we may have additional comments.
Summary Historical Financial Data, page 10
Selected Historical Financial Data, page 23
1. We note your presentation of EBITDA includes an adjustment for impairment of intangible assets. Measures referred to as EBITDA should not exclude items other than interest, taxes, depreciation and amortization. Please revise your presentation accordingly. Refer to Question 103.01 of the Compliance and Disclosure Interpretations for Non -GAAP Financial Measures. Please also revise your presentation of EBITDA in future Exchange Act filings.
Robert P. Capps Mitcham Industries, Inc. May 10 , 201 6 Page 2
You may contact Melinda Hooker (Staff Accountant) at 202-551-3732 or Dale Welcome (Staff Accountant ) at 202-551-3865 if you have questions regarding comments on the financial statements and related matters. Please contact Frank Pigott (Staff Attorney) at 202-551-3570 or me at 202-551-3729 with any other questions.
Sincerely,
/s/ Craig S livka, for
Show Raw Text
May 10 , 201 6 Mail Stop 4631 Via E -Mail Robert P. Capps Co-Chief Executive Officer and Chief Financial Officer Mitcham Industries, Inc. 8141 SH 75 South P.O. Box 1175 Huntsville, TX 77342 Re: Mitcham Industries, Inc. Amendment No. 2 to Registration Statement on Form S -1 Filed April 22, 2016 File No. 333 -208177 Dear Mr. Capps : We have reviewed your amended registration statement and have the following comment . Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in y our response. After reviewing any amendment to your registration statement and the information you provide in response to this comment , we may have additional comments. Summary Historical Financial Data, page 10 Selected Historical Financial Data, page 23 1. We note your presentation of EBITDA includes an adjustment for impairment of intangible assets. Measures referred to as EBITDA should not exclude items other than interest, taxes, depreciation and amortization. Please revise your presentation accordingly. Refer to Question 103.01 of the Compliance and Disclosure Interpretations for Non -GAAP Financial Measures. Please also revise your presentation of EBITDA in future Exchange Act filings. Robert P. Capps Mitcham Industries, Inc. May 10 , 201 6 Page 2 You may contact Melinda Hooker (Staff Accountant) at 202-551-3732 or Dale Welcome (Staff Accountant ) at 202-551-3865 if you have questions regarding comments on the financial statements and related matters. Please contact Frank Pigott (Staff Attorney) at 202-551-3570 or me at 202-551-3729 with any other questions. Sincerely, /s/ Craig S livka, for Pamela Long Assistant Director Office of Manufacturing and Construction cc: Gillian A. Hobson Vinson & Elkins, L.L.P.