SEC Comment Letter for GOODRICH PETROLEUM CORP (CIK 0000943861) — Sep 15, 2005
GOODRICH PETROLEUM CORP (CIK 0000943861)
Date: Sept. 15, 2005 · CIK: 0000943861 · Accession: 0000000000-05-047813
AI Filing Summary & Sentiment
Referenced dates: July 26, 2005
Letter
September 15, 2005 Mr. D. Hughes Watler, Jr. Chief Financial Officer Goodrich Petroleum Corporation 808 Travis St., Suite 1320 Houston, Texas 77002
Re: Goodrich Petroleum Corporation Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 25, 2005 Forms 10-Q for Fiscal Quarters Ended March 31, 2005 and June 30, 2005 Filed May 10, 2005 and August 15, 2005 Response Letters Dated July 26, 2005 and August 24, 2005 File No. 1-12719
Dear Mr. Watler:
We have reviewed your response letter and have the following comment. We have limited our review of your filing to the issue we have addressed in our comment. Please provide a written response to our comment. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2004
Engineering Comment
NOTE P-Supplemental Oil and Gas Reserve Information (Unaudited), page
1. In your response 3, you request that we "consider accepting these enhanced disclosures in our Fiscal Year 2005 10-K together with corresponding disclosure on material differences arising between year-end 2004 and 2005 reserves." Please affirm to us that you will make such disclosures beginning with your 2005 Form 10-K. Closing Comments
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact Regina Balderas, Staff Accountant, at (202) 551- 3722 or Jill Davis, Branch Chief, at (202) 551-3683 if you have questions regarding comments on the financial statements and related matters. You may contact Ronald Winfrey, Petroleum Engineer, at (202) 551-3703 with questions about engineering comments. Please contact me at (202) 551-3740 with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
September 15, 2005
Mr. D. Hughes Watler, Jr.
Chief Financial Officer
Goodrich Petroleum Corporation
808 Travis St., Suite 1320
Houston, Texas 77002
Re: Goodrich Petroleum Corporation
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 25, 2005
Forms 10-Q for Fiscal Quarters Ended
March 31, 2005 and June 30, 2005
Filed May 10, 2005 and August 15, 2005
Response Letters Dated July 26, 2005 and August 24, 2005
File No. 1-12719
Dear Mr. Watler:
We have reviewed your response letter and have the following
comment. We have limited our review of your filing to the issue
we
have addressed in our comment. Please provide a written response
to
our comment. Please be as detailed as necessary in your
explanation.
In our comment, we may ask you to provide us with information so
we
may better understand your disclosure. After reviewing this
information, we may raise additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2004
Engineering Comment
NOTE P-Supplemental Oil and Gas Reserve Information (Unaudited),
page
55
1. In your response 3, you request that we "consider accepting
these
enhanced disclosures in our Fiscal Year 2005 10-K together with
corresponding disclosure on material differences arising between
year-end 2004 and 2005 reserves." Please affirm to us that you
will
make such disclosures beginning with your 2005 Form 10-K.
Closing Comments
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. Please furnish a
letter
that keys your response to our comment and provides any requested
information. Detailed letters greatly facilitate our review.
Please
understand that we may have additional comments after reviewing
your
response to our comment.
You may contact Regina Balderas, Staff Accountant, at (202)
551-
3722 or Jill Davis, Branch Chief, at (202) 551-3683 if you have
questions regarding comments on the financial statements and
related
matters. You may contact Ronald Winfrey, Petroleum Engineer, at
(202) 551-3703 with questions about engineering comments. Please
contact me at (202) 551-3740 with any other questions.
Sincerely,
H. Roger Schwall
Assistant Director
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Mr. D. Hughes Watler, Jr.
Goodrich Petroleum Corporation
September 15, 2005
page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010
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