SEC Comment Letter for PROFESSIONAL VETERINARY PRODUCTS — May 12, 2005
PROFESSIONAL VETERINARY PRODUCTS LTD /NE/ (CIK 0000947425)
Date: May 12, 2005 · CIK: 0000947425 · Accession: 0000000000-05-023630
AI Filing Summary & Sentiment
Referenced dates: April 11, 2005
Letter
May 12, 2005 By Facsimile and U.S. Mail Dr. Lionel L. Reilly President and Chief Executive Officer Professional Veterinary Products, LTD. 10077 South 134th Street Omaha, NE 68138
Re: Form 10-K for the Year Ended July 31, 2004 File No. 0-26326
Dear Dr. Reilly:
We have reviewed your response dated April 25, 2005 to our comment letter dated April 11, 2005 and have the following additional comments. Please understand that the purpose of our review is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for the Year Ended July 31, 2004
Consolidated Balance Sheets, page F-2
1. We note your response to prior comment 2. Topic D-98 states that Rule 5-02.28 of Regulation S-X provides analogous guidance for equity instruments that are not preferred securities. Explain why common shares that remain classified in stockholders` equity that are not within the scope of SFAS 150 are not presented outside of permanent equity where redemption, for cash, is outside of your control upon notice from the shareholder. In your response please provide the number of shares and outstanding amounts for each class of shareholders at July 31, 2004 and revise as appropriate.
Consolidated Statements of Stockholders` Equity, page F-4
2. We note your response to prior comment 3. Please state on the face of the balance sheet or disclose in a note the amount and number of common shares receivable as of your balance sheet dates. See Rule 5-02.30 of Regulation S-X.
Please send us your response to our comment within 10 business days from the date of this letter or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your response to our comment. Your supplemental response letter should be submitted in electronic form on EDGAR as a correspondence file. Refer to Rule 101(a) of Regulation S-T.
If you have any questions regarding our comments, please direct them to Brian V. McAllister at (202) 551-3341 or, Donna Di Silvio at (202) 551-3202, or in her absence to the undersigned at (202) 551-3841.
Sincerely,
Michael Moran
Accounting Branch
Chief
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Mail Stop 3-8
May 12, 2005
By Facsimile and U.S. Mail
Dr. Lionel L. Reilly
President and Chief Executive Officer
Professional Veterinary Products, LTD.
10077 South 134th Street
Omaha, NE 68138
Re: Form 10-K for the Year Ended July 31, 2004
File No. 0-26326
Dear Dr. Reilly:
We have reviewed your response dated April 25, 2005 to our
comment letter dated April 11, 2005 and have the following
additional
comments. Please understand that the purpose of our review is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. Feel free
to
call us at the telephone numbers listed at the end of this letter.
Form 10-K for the Year Ended July 31, 2004
Consolidated Balance Sheets, page F-2
1. We note your response to prior comment 2. Topic D-98 states
that
Rule 5-02.28 of Regulation S-X provides analogous guidance for
equity
instruments that are not preferred securities. Explain why common
shares that remain classified in stockholders` equity that are not
within the scope of SFAS 150 are not presented outside of
permanent
equity where redemption, for cash, is outside of your control
upon
notice from the shareholder. In your response please provide the
number of shares and outstanding amounts for each class of
shareholders at July 31, 2004 and revise as appropriate.
Consolidated Statements of Stockholders` Equity, page F-4
2. We note your response to prior comment 3. Please state on the
face of the balance sheet or disclose in a note the amount and
number
of common shares receivable as of your balance sheet dates. See
Rule
5-02.30 of Regulation S-X.
Please send us your response to our comment within 10
business
days from the date of this letter or tell us when you will provide
us
with a response. Please understand that we may have additional
comments after reviewing your response to our comment. Your
supplemental response letter should be submitted in electronic
form
on EDGAR as a correspondence file. Refer to Rule 101(a) of
Regulation S-T.
If you have any questions regarding our comments, please
direct them to Brian V. McAllister at (202) 551-3341 or, Donna Di
Silvio at (202) 551-3202, or in her absence to the undersigned at
(202) 551-3841.
Sincerely,
Michael Moran
Accounting Branch
Chief
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Dr. Lionel L. Reilly
Professional Veterinary Products Ltd.
May 12, 2005
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