SEC Comment Letter for RUSH ENTERPRISES INC \TX\ (RUSHA, RUSHB) (CIK 0001012019) (RUSHA) — Jan 29, 2010
RUSH ENTERPRISES INC \TX\ (RUSHA, RUSHB) (CIK 0001012019)
Date: Jan. 29, 2010 · CIK: 0001012019 · Accession: 0000000000-10-006041
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 23, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-3561 DIVISION OF CORPORATION FINANCE Mail Stop 3561 January 29, 2010 W.M. “Rusty” Rush President and Chief Executive Officer Rush Enterprises, Inc. 555 IH3 35 South New Braunfels, TX 78130
Re: Rush Enterprises, Inc. Form 10-Q for the Fiscal Quarter Ended September 31, 2009 Filed November 9, 2009 File No. 0-20797
Dear Mr. Rush: We have reviewed your response dated January 15, 2010 and have the following comment. Financial Statements for the Period Ended September 30, 2009
Note 2. Goodwill and Other In tangible Assets, page 6
1. We read your response to comment 20 from our letter dated December 23, 2009. We note that SFAS 142 says that the amount of goodwill to be included in the carrying amount of the portion of the reporting unit to be disposed of shall be based on th e relative fair values of the business to be disposed of and the portion of the reporting unit to be retained. However, it appears you have used the relative gr oss profit of the busine ss to be disposed of to determine the amount of goodwill to include in the carrying amount. Please explain to us why you believe that relative gross profit is the sa me as or approximates relative fair value. Refer to ASC 350-20-35-53.
Please respond to this comment within 10 business days or tell us when you will provide us with a response.
W.M. “Rusty” Rush Rush Enterprises, Inc. January 29, 2010 Page 2 Please contact Elizabeth Sellars, Staff Acc ountant at (202) 551-3348 or Jennifer Thompson, Accounting Branch Chief at (202) 551-3737 if you have questions regarding comments on the financial statements and related matters. You may contact Brigitte Lippmann, Special Counsel, at (202) 551-3713 or me at (202) 551- 3720 with any other questions.
Sincerely,
H. Christopher Owings
A s s i s t a n t D i r e c t o r
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561
DIVISION OF
CORPORATION FINANCE
Mail Stop 3561 January 29, 2010 W.M. “Rusty” Rush President and Chief Executive Officer Rush Enterprises, Inc. 555 IH3 35 South New Braunfels, TX 78130
Re:
Rush Enterprises, Inc.
Form 10-Q for the Fiscal Quarter Ended September 31, 2009
Filed November 9, 2009
File No. 0-20797
Dear Mr. Rush: We have reviewed your response dated January 15, 2010 and have the following comment. Financial Statements for the Period Ended September 30, 2009
Note 2. Goodwill and Other In tangible Assets, page 6
1. We read your response to comment 20 from our letter dated December 23, 2009. We note
that SFAS 142 says that the amount of goodwill to be included in the carrying amount of
the portion of the reporting unit to be disposed of shall be based on th e relative fair values
of the business to be disposed of and the portion of the reporting unit to be retained.
However, it appears you have used the relative gr oss profit of the busine ss to be disposed of
to determine the amount of goodwill to include in the carrying amount. Please explain to us why you believe that relative gross profit is the sa me as or approximates relative fair value.
Refer to ASC 350-20-35-53.
Please respond to this comment within 10 business days or tell us when you will provide us
with a response.
W.M. “Rusty” Rush
Rush Enterprises, Inc. January 29, 2010 Page 2 Please contact Elizabeth Sellars, Staff Acc ountant at (202) 551-3348 or Jennifer Thompson,
Accounting Branch Chief at (202) 551-3737 if you have questions regarding comments on the
financial statements and related matters. You may contact Brigitte Lippmann, Special Counsel, at (202) 551-3713 or me at (202) 551- 3720 with any other questions.
Sincerely,
H. Christopher Owings
A s s i s t a n t D i r e c t o r