SEC Comment Letter for RUSH ENTERPRISES INC \TX\ (RUSHA, RUSHB) (CIK 0001012019) (RUSHA) — Dec 30, 2015
RUSH ENTERPRISES INC \TX\ (RUSHA, RUSHB) (CIK 0001012019)
Date: Dec. 30, 2015 · CIK: 0001012019 · Accession: 0000000000-15-059906
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-20797
Letter
Mail Stop 3561 December 30, 2015 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, 2014 Filed March 2, 2015 File No. 000-20797
Dear Mr. Rush :
We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Item 1A. Risk Factors
Risks Related to Our Business
We are dependent upon PACCAR for the supply of Peterbilt trucks and parts, the sale of which generates the majority of our revenues, page 15
1. We note that your sales and service relationships with Peterbilt represent a significant portion of your revenues. We also note your risk factor indicating that contracts with Peterbilt have begun to expire and will continue to do so throughout 2017. Please tell us the significance of these expiring contracts and their impact on your operations. Also, please tell us management’s expectations for renewal and any efforts to mitigate the disclosed risk s. In future filings, please include these expectations and efforts.
W.M. “Rusty” Rush Rush Enterprises, In c. December 30, 2015 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of t he disclosures they have made.
In respon ding to our comments, please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company 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 contact Dean Brazier, Staff Attorney , at (202) 551 -3485 or me at (202) 551 -3720 with any other questions.
Sincerely,
/s/ Lisa M. Kohl for
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Mail Stop 3561 December 30, 2015 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, 2014 Filed March 2, 2015 File No. 000-20797 Dear Mr. Rush : We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Item 1A. Risk Factors Risks Related to Our Business We are dependent upon PACCAR for the supply of Peterbilt trucks and parts, the sale of which generates the majority of our revenues, page 15 1. We note that your sales and service relationships with Peterbilt represent a significant portion of your revenues. We also note your risk factor indicating that contracts with Peterbilt have begun to expire and will continue to do so throughout 2017. Please tell us the significance of these expiring contracts and their impact on your operations. Also, please tell us management’s expectations for renewal and any efforts to mitigate the disclosed risk s. In future filings, please include these expectations and efforts. W.M. “Rusty” Rush Rush Enterprises, In c. December 30, 2015 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of t he disclosures they have made. In respon ding to our comments, please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company 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 contact Dean Brazier, Staff Attorney , at (202) 551 -3485 or me at (202) 551 -3720 with any other questions. Sincerely, /s/ Lisa M. Kohl for Mara Ransom Assistant Director Office of Consumer Products cc: Derrek Weaver