SEC Company Response from WESTAFF INC (CIK 0000931911) — Sep 12, 2005
WESTAFF INC (CIK 0000931911)
Date: Sept. 12, 2005 · CIK: 0000931911 · Accession: 0001104659-05-043643
AI Filing Summary & Sentiment
Referenced dates: July 25, 2005
Letter
Division of Corporation Finance Form 10-K for Fiscal Year Ended October 30, 2004 Filed January 28, 2005 Forms 10-Q for Fiscal Year Ended April 16, 2005 File No. 0-24990
Dear Ms. Bashaw:
Pursuant to Rule 101(a)(1)(iii) of Regulation S-T, Westaff, Inc., a Delaware corporation (the “Company”) is transmitting via EDGAR this correspondence in order to confirm Westaff’s understanding of our phone conversation from earlier today relating to items 4 and 7 of your letter dated July 25, 2005 and our response dated August 3, 2005. We welcome your insight and appreciate the purpose of the comments, which we understand are designed to enhance the overall disclosure of our filings. Our response appears below. The numbering of the Company’s response corresponds to the numbering in the Staff’s original letter.
Form 10-K for Fiscal Year Ended October 30, 2004
4. This will confirm that Westaff will enhance its disclosures in future periods to include a discussion on the nature of the franchise agents’ share of gross profit and why this is not considered to be a cost of service.
7. This will confirm that for future filings, Westaff will include in its footnotes a schedule reflecting its goodwill balances by reportable segment and will further provide a rollforward of such balances identifying any changes in balances by reportable segment.
Should you have any questions regarding this letter please contact the undersigned at 925-256-1518.
Sincerely,
/s/ Dirk A. Sodestrom
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CORRESP 1 filename1.htm 298 North Wiget Lane, Walnut Creek , CA 94598 • 1.877.Westaff www.westaff.com September 9, 2005 U.S. Securities and Exchange Commission Via Facsimile Transmission Division of Corporation Finance & Edgar Transmission Mail Stop 0407 100 F Street, N.E. Room 3528 Washington, DC 20549 Attn: Ms. Christine Bashaw Westaff, Inc. Form 10-K for Fiscal Year Ended October 30, 2004 Filed January 28, 2005 Forms 10-Q for Fiscal Year Ended April 16, 2005 File No. 0-24990 Dear Ms. Bashaw: Pursuant to Rule 101(a)(1)(iii) of Regulation S-T, Westaff, Inc., a Delaware corporation (the “Company”) is transmitting via EDGAR this correspondence in order to confirm Westaff’s understanding of our phone conversation from earlier today relating to items 4 and 7 of your letter dated July 25, 2005 and our response dated August 3, 2005. We welcome your insight and appreciate the purpose of the comments, which we understand are designed to enhance the overall disclosure of our filings. Our response appears below. The numbering of the Company’s response corresponds to the numbering in the Staff’s original letter. Form 10-K for Fiscal Year Ended October 30, 2004 4. This will confirm that Westaff will enhance its disclosures in future periods to include a discussion on the nature of the franchise agents’ share of gross profit and why this is not considered to be a cost of service. 7. This will confirm that for future filings, Westaff will include in its footnotes a schedule reflecting its goodwill balances by reportable segment and will further provide a rollforward of such balances identifying any changes in balances by reportable segment. Should you have any questions regarding this letter please contact the undersigned at 925-256-1518. Sincerely, /s/ Dirk A. Sodestrom Dirk A. Sodestrom Senior Vice President and Chief Financial Officer