SEC Comment Letter for ATI INC (ATI) (CIK 0001018963) (ATI) — Oct 17, 2013
ATI INC (ATI) (CIK 0001018963)
Date: Oct. 17, 2013 · CIK: 0001018963 · Accession: 0000000000-13-057236
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 25, 2013
Letter
October 17, 2013 Via E -mail Mr. Patrick DeCourcy Interim Chief Financial Officer Allegheny Technologies Inc orporat ed 1000 Six PPG Place Pittsburgh, PA 15222 -5479
Re: Allegheny Technologies Incorporat ed Form 10-K Filed February 28 , 2013 File No. 1-12001
Dear Mr. DeCourcy :
We have re ad your response dated October 9 , 2013 and have the following comment . Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provi de in response to this comment s, we may have additional comments.
Form 10 -Q for the period ended June 30, 2013
Note 11. Financial Information for Subsidiary and Guarantor Parent, page 16
1. We have read your response to comment 2 in our letter dated September 25, 2013. It appears separate disclosure of intercompany balances is warranted in each period. Therefore, please confirm that in future filings, beginning with your September 30, 2013 Form 10 -Q, you will present this information as a separate lin e item in the S -X Rule 3 -10 balance sheets.
You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3355 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Terence O ’Brien
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October 17, 2013 Via E -mail Mr. Patrick DeCourcy Interim Chief Financial Officer Allegheny Technologies Inc orporat ed 1000 Six PPG Place Pittsburgh, PA 15222 -5479 Re: Allegheny Technologies Incorporat ed Form 10-K Filed February 28 , 2013 File No. 1-12001 Dear Mr. DeCourcy : We have re ad your response dated October 9 , 2013 and have the following comment . Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provi de in response to this comment s, we may have additional comments. Form 10 -Q for the period ended June 30, 2013 Note 11. Financial Information for Subsidiary and Guarantor Parent, page 16 1. We have read your response to comment 2 in our letter dated September 25, 2013. It appears separate disclosure of intercompany balances is warranted in each period. Therefore, please confirm that in future filings, beginning with your September 30, 2013 Form 10 -Q, you will present this information as a separate lin e item in the S -X Rule 3 -10 balance sheets. You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3355 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Terence O ’Brien Terence O’Brien Branch Chief