SEC Comment Letter for ATI INC (ATI) (CIK 0001018963) (ATI) — Mar 22, 2011
ATI INC (ATI) (CIK 0001018963)
Date: March 22, 2011 · CIK: 0001018963 · Accession: 0000000000-11-017681
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12001, 333-171426
Letter
March 18, 2011 Via U.S. Mail and Facsimile Jon D. Walton Executive Vice President, Human Resources Chief Legal and Compliance Offi cer and Corporate Secretary Allegheny Technologies Incorporated 1000 Six PPG Place Pittsburgh, Pennsylvania 15222 Re: Allegheny Technologies Incorporated Amendment No. 3 to the Registration Statement on Form S-4 Filed February 10, 2011 File No. 333-171426 Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 28, 2011 File No. 001-12001
Dear Mr. Walton:
We have reviewed your response letter da ted March 10, 2011 and the above-referenced filings, and have the following comments.
Form 10-K for the fiscal year ended December 31, 2010
Legal Proceedings, page 14 1. We note your response to our prior comment five. Please revise future filings to clarify that there are no pending legal matters that you believ e could have a material adverse effect on your operations, as appropriate. Results of Operations, page 21
2. We note your response to our prior comment eight and the additional information that you provided supplementally. However, our refere nce to your High Performance Metals segment was just one example of an area where your discussion of your opera ting results could be improved. We continue to note that you cite several underlying factors that impact not only your High Performance Metals segment but also your other reportable segments such as changes in demand, increased shipments, raw ma terial prices and selling prices. Please revise future filings to quan tify the impact of these factor s on your revenu e and operating profit for each of your segments as well as your consolidated information, where practicable.
Jon D. Walton Allegheny Technologies Incorporated March 18, 2011 Page 2
You may contact Tricia Arme lin, Staff Accountant, at 202-551-3747, or John Hartz, Senior Assistant Chief Accountant, at 202-551-36 89 if you have questions regarding comments on the financial statements and related matters. Please contact Erin Jaskot, Staff Attorney, at 202-551-3442, or Craig Slivka, Special Counsel , at 202-551-3729 with any other questions.
Sincerely,
Pamela A. Long Assistant Director
cc: Ronald D. West, Esq. ( via facsimile at (412) 355-6501)
K&L Gates LLP Mark T. Plichta, Esq. ( via facsimile at (414) 297-4900)
Foley & Lardner
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March 18, 2011 Via U.S. Mail and Facsimile Jon D. Walton Executive Vice President, Human Resources Chief Legal and Compliance Offi cer and Corporate Secretary Allegheny Technologies Incorporated 1000 Six PPG Place Pittsburgh, Pennsylvania 15222 Re: Allegheny Technologies Incorporated Amendment No. 3 to the Registration Statement on Form S-4 Filed February 10, 2011 File No. 333-171426 Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 28, 2011 File No. 001-12001 Dear Mr. Walton: We have reviewed your response letter da ted March 10, 2011 and the above-referenced filings, and have the following comments. Form 10-K for the fiscal year ended December 31, 2010 Legal Proceedings, page 14 1. We note your response to our prior comment five. Please revise future filings to clarify that there are no pending legal matters that you believ e could have a material adverse effect on your operations, as appropriate. Results of Operations, page 21 2. We note your response to our prior comment eight and the additional information that you provided supplementally. However, our refere nce to your High Performance Metals segment was just one example of an area where your discussion of your opera ting results could be improved. We continue to note that you cite several underlying factors that impact not only your High Performance Metals segment but also your other reportable segments such as changes in demand, increased shipments, raw ma terial prices and selling prices. Please revise future filings to quan tify the impact of these factor s on your revenu e and operating profit for each of your segments as well as your consolidated information, where practicable. Jon D. Walton Allegheny Technologies Incorporated March 18, 2011 Page 2 You may contact Tricia Arme lin, Staff Accountant, at 202-551-3747, or John Hartz, Senior Assistant Chief Accountant, at 202-551-36 89 if you have questions regarding comments on the financial statements and related matters. Please contact Erin Jaskot, Staff Attorney, at 202-551-3442, or Craig Slivka, Special Counsel , at 202-551-3729 with any other questions. Sincerely, Pamela A. Long Assistant Director cc: Ronald D. West, Esq. ( via facsimile at (412) 355-6501) K&L Gates LLP Mark T. Plichta, Esq. ( via facsimile at (414) 297-4900) Foley & Lardner