SEC Comment Letter for FLOTEK INDUSTRIES (FTK) — May 26, 2010
FLOTEK INDUSTRIES INC/CN/ (FTK) (CIK 0000928054)
Date: May 26, 2010 · CIK: 0000928054 · Accession: 0000000000-10-029385
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
May 26, 2010
via U.S. mail and facsimile
Jesse E. Neyman Executive Vice President, Finance and Strategic Planning Flotek Industries, Inc. 2930 W. Sam Houston Pkwy N., Suite 300 Houston, Texas 77043
Re: Item 4.02 Form 8-K
Filed: May 21, 2010
File No. 1-13270
Dear Mr. Neyman:
We have reviewed your Item 4.02 Form 8-K for compliance with the form
requirements and have the following comment.
1. Please give us a comprehensive, detaile d description of how you identified the
error discussed in Item 4.02 of your Form 8-K. Provide us with a timeline detailing the important dates and events th at transpired, including when the error
was identified, significant communications about the error w ith your auditors,
board of directors, audit committee and others, when the decision was made to
revise the affected financial stat ements, the date you engaged UHY LLP
specifically to perform audit procedures re lating to the revision, and other relevant
events.
* * * *
Please respond to this comment within 5 business days, or tell us when you will
provide us with a response. Please provide us with a supplementa l response letter that
keys your response to our comment and provides any requested 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 reviewin g your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings reviewed by the sta ff to be certain that they have provided all
information investors require for an info rmed decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
Jesse E. Neyman
May 26, 2010 Page 2
In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in
their filings;
• staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing. If you have any questions regarding this comment, please direct them to Ernest
Greene, Staff Accountant, at (202) 551-3733 or , in his absence, to the undersigned at
(202) 551-3355. S i n c e r e l y , T e r e n c e O ’ B r i e n
Accounting Branch Chief