SEC Comment Letter 0000000000-23-003151 to RUSH ENTERPRISES INC \TX\ (RUSHA, RUSHB) (CIK 0001012019) (RUSHA)
RUSH ENTERPRISES INC \TX\ (RUSHA, RUSHB) (CIK 0001012019)
Date: March 29, 2023 · CIK: 0001012019 · Accession: 0000000000-23-003151
AI Filing Summary & Sentiment
File numbers found in text: 000-20797
Letter
United States securities and exchange commission logo March 29, 2023 Steven Keller Chief Financial 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, 2022 Filed February 23, 2023 File No. 000-20797 Dear Steven Keller: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 9A. Controls and Procedures Management's Annual Report on Internal Control over Financial Reporting, page 80 1.Please tell us why you have not disclosed management's assessment of your internal control over financial reporting, including a statement as to whether or not internal control over financial reporting is effective. Refer to Item 308(a)(3) of Regulation S-K. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameSteven Keller Comapany NameRush Enterprises, Inc. March 29, 2023 Page 2 FirstName LastName Steven Keller Rush Enterprises, Inc. March 29, 2023 Page 2 You may contact Scott Stringer at 202-551-3272 or Adam Phippen at 202-551-3336 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 29, 2023
Steven Keller
Chief Financial 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, 2022
Filed February 23, 2023
File No. 000-20797
Dear Steven Keller:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9A. Controls and Procedures
Management's Annual Report on Internal Control over Financial Reporting, page 80
1.Please tell us why you have not disclosed management's assessment of your internal
control over financial reporting, including a statement as to whether or not internal control
over financial reporting is effective. Refer to Item 308(a)(3) of Regulation S-K.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameSteven Keller
Comapany NameRush Enterprises, Inc.
March 29, 2023 Page 2
FirstName LastName
Steven Keller
Rush Enterprises, Inc.
March 29, 2023
Page 2
You may contact Scott Stringer at 202-551-3272 or Adam Phippen at 202-551-3336 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services