SEC Company Response from AMERIVEST PROPERTIES INC (CIK 0000927102) — Jul 25, 2005
AMERIVEST PROPERTIES INC (CIK 0000927102)
Date: July 25, 2005 · CIK: 0000927102 · Accession: 0001104659-05-033804
AI Filing Summary & Sentiment
Referenced dates: July 13, 2005
Letter
Division of Corporation Finance Securities and Exchange Commission Form 10K for Fiscal Year Ended December 31, Form 10-Q for Fiscal Quarter Ended March 31, File No. 1-14462 Letter dated July 13, 2005
Dear Mr. Flinn:
This letter is in response to your letter of July 13, 2005 regarding the disclosure by AmeriVest Properties Inc. (“AmeriVest” or the “Company”) of same store net operating income. Based on our review of your initial correspondence and as recommended in the above-referenced letter, it is the Company’s intent for all future Form 10-K or Form 10-Q filings with the Securities and Exchange Commission to exclude any discussion of same store net operating income in Management’s Discussion and Analysis or elsewhere within the document. Any non-GAAP measures on a consolidated basis will be reconciled to an appropriate GAAP measure and will include discussion of how management uses this information and why this information might be useful to a current or potential investor. “Same store” versus consolidated results will be analyzed within the revenue and expense sections of the MD&A only and include such discussion.
We appreciate your timely response to our initial reply and your succinct guidance regarding the issue reviewed. Please do not hesitate to call with any further questions. It was a pleasure working with you.
Sincerely,
/s/ KATHRYN L. HALE
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CORRESP 1 filename1.htm July 22, 2005 Thomas Flinn Staff Accountant Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Via Facsimile Transmittal (202 772-9209), by USPS regular mail and via Edgar Re: AmeriVest Properties Inc. Form 10K for Fiscal Year Ended December 31, 2004 Form 10-Q for Fiscal Quarter Ended March 31, 2005 File No. 1-14462 Letter dated July 13, 2005 Dear Mr. Flinn: This letter is in response to your letter of July 13, 2005 regarding the disclosure by AmeriVest Properties Inc. (“AmeriVest” or the “Company”) of same store net operating income. Based on our review of your initial correspondence and as recommended in the above-referenced letter, it is the Company’s intent for all future Form 10-K or Form 10-Q filings with the Securities and Exchange Commission to exclude any discussion of same store net operating income in Management’s Discussion and Analysis or elsewhere within the document. Any non-GAAP measures on a consolidated basis will be reconciled to an appropriate GAAP measure and will include discussion of how management uses this information and why this information might be useful to a current or potential investor. “Same store” versus consolidated results will be analyzed within the revenue and expense sections of the MD&A only and include such discussion. We appreciate your timely response to our initial reply and your succinct guidance regarding the issue reviewed. Please do not hesitate to call with any further questions. It was a pleasure working with you. Sincerely, /s/ KATHRYN L. HALE Kathryn L. Hale Chief Financial Officer AmeriVest Properties Inc.