SEC Comment Letter for FLOTEK INDUSTRIES (FTK) — Dec 23, 2015
FLOTEK INDUSTRIES INC/CN/ (FTK) (CIK 0000928054)
Date: Dec. 23, 2015 · CIK: 0000928054 · Accession: 0000000000-15-059358
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 17, 2015
Letter
Mail Stop 4631 December 23, 2015 Via E -mail Mr. Robert M. Schmitz Chief Financial Officer Flotek Industries, Inc. 10603 West Sam Houston Parkway North, Suite 300 Houston , Texas 7 7064
RE: Flotek Industries, Inc. Form 10 -K for the Year E nded December 31, 2014 Filed January 27 , 2015 Form 10 -Q for the Period Ended September 30, 2015 Filed October 21 , 2015 Response dated December 17, 2015 File No. 1 -13270
Dear Mr. Schmitz :
We have reviewed your response letter dated December 17, 2015 and have the following comments . In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments , we may have additional comments.
Form 10 -Q for the Period Ended September 30, 2015
Management’s Discussion and Analysis
1. We note your response to com ment 4 of our letter dated June 24 , 2015. Your response to comment 3 indicates that the drop off in business resulting from declines in oil prices and the active drilling rig count was an event or circumstance that caused you to consider whether goodwill should be tested for impairment and led t o you to test the goodwill of the Teledrift reporting unit for impairment. It is not clear what considerations were given to these same factors in determining whether assets or asset groups related to your
Mr. Robert M. Schmitz Flotek Industries, Inc. December 23, 2015 Page 2
Drilling Technologies and Production Technologies segments should be tested for impairment. In this regard, please help us better understand the nature of the preliminary analyses that you performed which did not indicate that the carrying amount of property and equipment within these segments would not be recoverable. Please also clarify whether there are specific assets or asset groups associated with the business of repairing motors in the South region which you have now decided to exit or other assets that would be impacted by your reduction in moto r fleet in the North region.
If you have any questions regarding these comments, please direct them to Nudrat Salik, Staff Accountant, at (202) 551 -3692 or, in her absence, to me at (202) 551 -3355.
Sincerely,
/s/ Terence O ’Brien
Show Raw Text
Mail Stop 4631
December 23, 2015
Via E -mail
Mr. Robert M. Schmitz
Chief Financial Officer
Flotek Industries, Inc.
10603 West Sam Houston Parkway North, Suite 300
Houston , Texas 7 7064
RE: Flotek Industries, Inc.
Form 10 -K for the Year E nded December 31, 2014
Filed January 27 , 2015
Form 10 -Q for the Period Ended September 30, 2015
Filed October 21 , 2015
Response dated December 17, 2015
File No. 1 -13270
Dear Mr. Schmitz :
We have reviewed your response letter dated December 17, 2015 and have the following
comments . In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments , we may have additional comments.
Form 10 -Q for the Period Ended September 30, 2015
Management’s Discussion and Analysis
1. We note your response to com ment 4 of our letter dated June 24 , 2015. Your response to
comment 3 indicates that the drop off in business resulting from declines in oil prices and
the active drilling rig count was an event or circumstance that caused you to consider
whether goodwill should be tested for impairment and led t o you to test the goodwill of
the Teledrift reporting unit for impairment. It is not clear what considerations were given
to these same factors in determining whether assets or asset groups related to your
Mr. Robert M. Schmitz
Flotek Industries, Inc.
December 23, 2015
Page 2
Drilling Technologies and Production Technologies segments should be tested for
impairment. In this regard, please help us better understand the nature of the preliminary
analyses that you performed which did not indicate that the carrying amount of property
and equipment within these segments would not be recoverable. Please also clarify
whether there are specific assets or asset groups associated with the business of repairing
motors in the South region which you have now decided to exit or other assets that would
be impacted by your reduction in moto r fleet in the North region.
If you have any questions regarding these comments, please direct them to Nudrat Salik,
Staff Accountant, at (202) 551 -3692 or, in her absence, to me at (202) 551 -3355.
Sincerely,
/s/ Terence O ’Brien
Terence O’Brien
Accounting Branch Chief
Office of Manufacturing and Construction