SEC Company Response from GOODRICH PETROLEUM CORP (CIK 0000943861) — Sep 19, 2005
GOODRICH PETROLEUM CORP (CIK 0000943861)
Date: Sept. 19, 2005 · CIK: 0000943861 · Accession: 0001193125-05-187490
AI Filing Summary & Sentiment
Referenced dates: August 24, 2005, September 15, 2005
Letter
Response Letter
[Goodrich Petroleum Corporation Letterhead]
September 19, 2005
VIA EDGAR AND FAX
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W., Stop 4-5
Washington, D.C. 20549
Attn: Ms. Regina Balderas
Division of Corporation Finance
Re: Goodrich Petroleum Corporation
Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 25, 2005
Form 10-Q for Fiscal Quarter Ended March 31, 2005
Filed May 10, 2005
Response Letter Dated August 24, 2005
File No. 1-12719
Ladies and Gentlemen:
On behalf of Goodrich Petroleum Corporation (the “Company”), this letter sets forth the Company’s responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its comment letter dated September 15, 2005 (the “Comment Letter”) with respect to the Company’s Annual Report on Form 10-K for the Year Ended December 31, 2004 and Quarterly Report on Form 10-Q for the Quarter Ended March 31, 2005. For your convenience, we have repeated in italics each comment of the Staff exactly as given in the Comment Letter and set forth below each such comment is the Company’s response.
Comment 1:
Engineering Comments
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 Form 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.
We hereby affirm that we will provide enhanced disclosures in our 2005 Form 10-K of the material historical differences between our year-end 2003 and 2004 reserves together with corresponding disclosure on material differences arising between year-end 2004 and 2005 reserves.
Securities and Exchange Commission
September 19, 2005
Page 2
Should you have any questions or clarifications regarding our responses, please do not hesitate to contact the undersigned by telephone at 713-780-9494.
Very truly yours,
/s/ D. Hughes Watler
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CORRESP 1 filename1.htm Response Letter [Goodrich Petroleum Corporation Letterhead] September 19, 2005 VIA EDGAR AND FAX Division of Corporation Finance Securities and Exchange Commission 450 Fifth Street, N.W., Stop 4-5 Washington, D.C. 20549 Attn: Ms. Regina Balderas Division of Corporation Finance Re: Goodrich Petroleum Corporation Form 10-K for Fiscal Year Ended December 31, 2004 Filed March 25, 2005 Form 10-Q for Fiscal Quarter Ended March 31, 2005 Filed May 10, 2005 Response Letter Dated August 24, 2005 File No. 1-12719 Ladies and Gentlemen: On behalf of Goodrich Petroleum Corporation (the “Company”), this letter sets forth the Company’s responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its comment letter dated September 15, 2005 (the “Comment Letter”) with respect to the Company’s Annual Report on Form 10-K for the Year Ended December 31, 2004 and Quarterly Report on Form 10-Q for the Quarter Ended March 31, 2005. For your convenience, we have repeated in italics each comment of the Staff exactly as given in the Comment Letter and set forth below each such comment is the Company’s response. Comment 1: Engineering Comments 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 Form 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. We hereby affirm that we will provide enhanced disclosures in our 2005 Form 10-K of the material historical differences between our year-end 2003 and 2004 reserves together with corresponding disclosure on material differences arising between year-end 2004 and 2005 reserves. Securities and Exchange Commission September 19, 2005 Page 2 Should you have any questions or clarifications regarding our responses, please do not hesitate to contact the undersigned by telephone at 713-780-9494. Very truly yours, /s/ D. Hughes Watler D. Hughes Watler, Jr. Chief Financial Officer