SEC Company Response from PRO TECH COMMUNICATIONS INC (CIK 0000945481) — Apr 21, 2005
PRO TECH COMMUNICATIONS INC (CIK 0000945481)
Date: April 21, 2005 · CIK: 0000945481 · Accession: 0000945481-05-000002
AI Filing Summary & Sentiment
File numbers found in text: 000-28602
Letter
April 21, 2005 VIA U.S. MAIL ------------- Mr. Larry Spirgel Assistant Director Division of Corporation Finance United States Securities and Exchange Commission Mail Stop 0407 450 Fifth Street, N.W. Washington, D.C. 20549
RE: Pro Tech Communications, Inc. Form 10-K for the fiscal year ended December 31, 2004 Filed March 29, 2005 File No. 000-28602
Dear Mr. Spirgel:
Pro Tech Communications, Inc. (referred to below as "we" or "our") is submitting this letter in response to your comment letter of April 7, 2005 with respect to the above-referenced filing of our Form 10-K. For your convenience, the text of the comment from your April 7, 2005 letter has been reproduced below.
Statements of Operations, page F-3 ----------------------------------
1. Since the captions "cost of goods sold" and "gross profit" exclude depreciation and amortization for property and equipment and licenses directly attributed to the generation of revenue, we believe that this presentation inappropriately reports a figure for income before depreciation and amortization. As required by SAB Topic 11:B, confirm that you will revise your presentation in future filings to either reclassify the applicable depreciation to "cost of goods sold" or remove the subtotal and caption "gross profit" and indicate the amount of applicable depreciation that is excluded from "cost of goods sold."
Response to Comment 1: ----------------------
We will revise our presentation in future filings with the Commission to remove the subtotal and caption "gross profit" and indicate the amount of applicable depreciation and amortization that is excluded from our "cost of goods sold."
Orange Blossom Mall 772-464-5100 (tel) 4492 Okeechobee Road 772-464-6644 (fax) Ft. Pierce, FL 34947 www.protechcommunications.com
<PAGE>
We acknowledge that:
o We are responsible for the adequacy and accuracy of the disclosure in our Form 10-K for the fiscal year ended December 31, 2004;
o Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to our Form 10-K for the fiscal year ended December 31, 2004; and
o We may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please feel free to call me at (203) 226-4447 ext. 3533, or our Senior Counsel Michael Palmieri, Esq. at (203) 226-4447 ext 3519 with any questions you may have.
Sincerely,
/s/ Mary Christian-Hein
-------------------------------
Mary Christian-Hein
Sr. Vice President, Chief Financial Officer
& Treasurer
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
[Pro Tech Communications, Inc. Letterhead]_______________________________
Mary Christian-Hein
Sr. Vice President, Chief Financial Officer
& Treasurer
20 Ketchum Street
Westport, CT 06880
Telephone 203-226-4447, ext. 3533
Facsimile 203-226-4338
E-mail mhein@nctgroupinc.com
April 21, 2005
VIA U.S. MAIL
-------------
Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
United States Securities and Exchange Commission
Mail Stop 0407
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: Pro Tech Communications, Inc.
Form 10-K for the fiscal year ended December 31, 2004
Filed March 29, 2005
File No. 000-28602
Dear Mr. Spirgel:
Pro Tech Communications, Inc. (referred to below as "we" or "our") is submitting
this letter in response to your comment letter of April 7, 2005 with respect to
the above-referenced filing of our Form 10-K. For your convenience, the text of
the comment from your April 7, 2005 letter has been reproduced below.
Statements of Operations, page F-3
----------------------------------
1. Since the captions "cost of goods sold" and "gross profit" exclude
depreciation and amortization for property and equipment and licenses
directly attributed to the generation of revenue, we believe that this
presentation inappropriately reports a figure for income before
depreciation and amortization. As required by SAB Topic 11:B, confirm that
you will revise your presentation in future filings to either reclassify
the applicable depreciation to "cost of goods sold" or remove the subtotal
and caption "gross profit" and indicate the amount of applicable
depreciation that is excluded from "cost of goods sold."
Response to Comment 1:
----------------------
We will revise our presentation in future filings with the Commission to remove
the subtotal and caption "gross profit" and indicate the amount of applicable
depreciation and amortization that is excluded from our "cost of goods sold."
Orange Blossom Mall 772-464-5100 (tel)
4492 Okeechobee Road 772-464-6644 (fax)
Ft. Pierce, FL 34947 www.protechcommunications.com
<PAGE>
We acknowledge that:
o We are responsible for the adequacy and accuracy of the disclosure in
our Form 10-K for the fiscal year ended December 31, 2004;
o Staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission from taking any action with respect to
our Form 10-K for the fiscal year ended December 31, 2004; and
o We may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
Please feel free to call me at (203) 226-4447 ext. 3533, or our Senior Counsel
Michael Palmieri, Esq. at (203) 226-4447 ext 3519 with any questions you may
have.
Sincerely,
/s/ Mary Christian-Hein
-------------------------------
Mary Christian-Hein
Sr. Vice President, Chief Financial Officer
& Treasurer
cc: Mark Melnick, Esq.
Michael J. Palmieri, Esq.
</TEXT>
</DOCUMENT>