SEC Comment Letter for NWPX Infrastructure, (NWPX) — Aug 2, 2005
NWPX Infrastructure, Inc.
Date: Aug. 2, 2005 · CIK: 0001001385 · Accession: 0000000000-05-039854
AI Filing Summary & Sentiment
Referenced dates: July 28, 2005
Letter
August 2, 2005 via U.S. mail and facsimile John Murakami Chief Financial Officer Northwest Pipe Company 200 S.W. Market Street Portland, Oregon 97201
RE: Northwest Pipe Company Form 10-K for the fiscal year ended December 31, 2004 Filed March 11, 2005 File No. 0-27140
Dear Mr. Murakami:
We have reviewed your response letter dated July 28, 2005 and have the following additional comment.
Form 10-K for the year ended December 31, 2004
Segments, Prior Comment 7 1. You state that the Poz-Loc Traffic Systems are not considered a reportable segment because discrete financial information is not available. It is unclear to us how you are able to make decisions concerning the allocation of resources to this business, or to assess its performance in the absence of discrete financial information. You say that you combine the information of Poz-Loc Traffic Systems with Tubular Products. Please provide us with the pre-combined information for Poz-Loc Traffic Systems. We assume that as part of your normal internal control structure you require information to assess this ongoing business. Provide us with an example of your internal management reports for the Tubular Products.
We also note that the nature of Poz-Loc products is different than that of other Tubular products, requires specific and differing government approval and is sold through different marketing channels.
You say that you do not consider Propane Tanks to be a reportable segment as it does not meet the quantitative thresholds of paragraph 18. However this does not mean that it, or Poz-Loc, may be aggregated with another reportable segment unless it meets all of the aggregation criteria in paragraph 17. Considering the nature of the products, it does not appear that they meet such criteria.
* * * *
As appropriate, 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 provide any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment.
You may contact Tracey McKoy, Staff Accountant, at (202) 551- 3772 or, in her absence, John Hartz at (202) 551-3689 or me at (202) 551-3255 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Nili Shah
Branch Chief
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Mail Stop 7010
August 2, 2005
via U.S. mail and facsimile
John Murakami
Chief Financial Officer
Northwest Pipe Company
200 S.W. Market Street
Portland, Oregon 97201
RE: Northwest Pipe Company
Form 10-K for the fiscal year ended December 31, 2004
Filed March 11, 2005
File No. 0-27140
Dear Mr. Murakami:
We have reviewed your response letter dated July 28, 2005
and
have the following additional comment.
Form 10-K for the year ended December 31, 2004
Segments, Prior Comment 7
1. You state that the Poz-Loc Traffic Systems are not considered a
reportable segment because discrete financial information is not
available. It is unclear to us how you are able to make decisions
concerning the allocation of resources to this business, or to
assess
its performance in the absence of discrete financial information.
You say that you combine the information of Poz-Loc Traffic
Systems
with Tubular Products. Please provide us with the pre-combined
information for Poz-Loc Traffic Systems. We assume that as part of
your normal internal control structure you require information to
assess this ongoing business. Provide us with an example of your
internal management reports for the Tubular Products.
We also note that the nature of Poz-Loc products is different than
that of other Tubular products, requires specific and differing
government approval and is sold through different marketing
channels.
You say that you do not consider Propane Tanks to be a reportable
segment as it does not meet the quantitative thresholds of
paragraph
18. However this does not mean that it, or Poz-Loc, may be
aggregated
with another reportable segment unless it meets all of the
aggregation criteria in paragraph 17. Considering the nature of
the
products, it does not appear that they meet such criteria.
* * * *
As appropriate, 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
provide any requested supplemental information. Detailed response
letters greatly facilitate our review. Please file your response
letter on EDGAR. Please understand that we may have additional
comments after reviewing your response to our comment.
You may contact Tracey McKoy, Staff Accountant, at (202) 551-
3772 or, in her absence, John Hartz at (202) 551-3689 or me at
(202)
551-3255 if you have questions regarding comments on the financial
statements and related matters.
Sincerely,
Nili Shah
Branch Chief
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Mr. Murakami
Northwest Pipe Company
August 2, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
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