SEC Comment Letter for RUSH ENTERPRISES INC \TX\ (RUSHA, RUSHB) (CIK 0001012019) (RUSHA) — Feb 6, 2013
RUSH ENTERPRISES INC \TX\ (RUSHA, RUSHB) (CIK 0001012019)
Date: Feb. 6, 2013 · CIK: 0001012019 · Accession: 0000000000-13-006896
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 31, 2012
Letter
February 5, 2013 Via E -mail W.M. “Rusty” Rush President and Chief Executive Officer Rush Enterprises, Inc. 555 IH 35 South New Braunfels, TX 78130
Re: Rush Enterprises, Inc. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed March 15, 2012 File No. 000 -20797
Dear Mr. W.M. “Rusty” Rush :
We have reviewed your response dated January 15, 2013 and have the following additional comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested respo nse. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the informa tion you provide in response to this comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2011
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 23
Year Ended December 31, 2011 Compared to Year Ended December 31, 2010, page 29
1. We note in your response to prior comment 1 in our letter dated December 31, 2012 that while revenue related to service sales represented less than 10% of total revenue for each of the periods reported, the service department gross profit margin represented approximately 30% of your total gross profit for each of the periods reported. Notwithstanding the close relationship between your parts and service departments, with a view to wards transparent disclosure, please revise future filings to supplement your discussion of the blended gross profit margin with a discussion of the impact the service department gross profit margin has on your overall gross profit margin.
W.M. “Rusty” Rush Rush Enterprises, Inc. February 5, 2013 Page 2
You may c ontact Jason Niethamer, Assistant Chief Accountant, at 202-551-3855 or Andrew Blume, Staff Accountant, at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202-551-3737 with any other questions.
Sincerely,
/s/ Jennifer Thompson
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February 5, 2013 Via E -mail W.M. “Rusty” Rush President and Chief Executive Officer Rush Enterprises, Inc. 555 IH 35 South New Braunfels, TX 78130 Re: Rush Enterprises, Inc. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed March 15, 2012 File No. 000 -20797 Dear Mr. W.M. “Rusty” Rush : We have reviewed your response dated January 15, 2013 and have the following additional comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested respo nse. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the informa tion you provide in response to this comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2011 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 23 Year Ended December 31, 2011 Compared to Year Ended December 31, 2010, page 29 1. We note in your response to prior comment 1 in our letter dated December 31, 2012 that while revenue related to service sales represented less than 10% of total revenue for each of the periods reported, the service department gross profit margin represented approximately 30% of your total gross profit for each of the periods reported. Notwithstanding the close relationship between your parts and service departments, with a view to wards transparent disclosure, please revise future filings to supplement your discussion of the blended gross profit margin with a discussion of the impact the service department gross profit margin has on your overall gross profit margin. W.M. “Rusty” Rush Rush Enterprises, Inc. February 5, 2013 Page 2 You may c ontact Jason Niethamer, Assistant Chief Accountant, at 202-551-3855 or Andrew Blume, Staff Accountant, at 202-551-3254 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202-551-3737 with any other questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief