SEC Comment Letter for MANCHESTER TECHNOLOGIES INC (CIK 0001023876) — Jun 7, 2005
MANCHESTER TECHNOLOGIES INC (CIK 0001023876)
Date: June 7, 2005 · CIK: 0001023876 · Accession: 0000000000-05-028361
AI Filing Summary & Sentiment
File numbers found in text: 000-21695
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
Room 4561
June 7, 2005
Mr. Barry Steinberg
Chairman, Chief Executive Officer and
Director
Manchester Technologies, Inc.
160 Oser Avenue
Hauppauge, NY 11788
Re: Manchester Technologies, Inc.
Form 10-K for the fiscal year ended July 31, 2004
Forms 10-Q for the fiscal quarters ended October 31, 2004 and
January
31, 2005
File No. 000-21695
Dear Mr. Steinberg:
We have reviewed your filings and have the following
comments.
Please note that we have limited our review to the areas addressed
below. Where indicated, we think you should revise your document
in
response to these comments. If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may raise additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10-K
Report of Independent Registered Public Accounting Firm, page F-2
1. It appears your independent registered public accounting firm
has
not signed the accountant`s report. Tell us how you considered
the
requirements of Article 2.02 of Regulation S-X to include a signed
report from the Company`s independent accounting firm.
Consolidated Statements of Cash Flows, page F-6
2. We note in your statements of cash flows you include separate
line
items within operating activities for losses from discontinued
operations and net cash provided by discontinued operations for
the
year ended July 31, 2004. However, we also note you have not
included a similar line item for discontinued operations for each
of
the years ended July 31, 2003 and 2002. Please tell us how you
considered footnote 10 of SFAS 95 in determining your presentation
for discontinued operations in your 10-K and subsequent 10-Q`s.
Also, if you intend to maintain the presentation of separate cash
flow information for discontinued operations, your statements of
cash
flows should separately disclose cash flows from investing and
financing activities related to discontinued operations.
Additionally, your disclosure of operating cash flows should show
all
components of operating cash flow related to discontinued
operations
rather than the net operating cash flows. Please tell us how you
intend to comply with these reporting requirements.
Note 1. Operations and Summary of Significant Accounting Policies
(d) Revenue Recognition, page F-7
3. We note on page 4 that you earn revenue as a result of fees
received for an extended warranty program in which the warranty is
provided by a third party warranty provider. Please tell us
whether
you record revenue earned from these sales on a gross or net basis
and provide the reasons for your conclusions. Refer to EITF 99-
19.
4. Additionally, please clarify the nature and terms of the
service
you provide in these arrangements and when you earn and recognize
the
related revenues. Furthermore, tell us the amount of revenue
earned
from these warranty sales for each year presented.
* * * * *
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information. Detailed cover
letters greatly facilitate our review. Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. 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 the disclosures they
have made.
In connection with responding to our comments, please
provide,
in writing, a 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.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Patrick Gilmore at (202) 551-3406, Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 or me at (202)
551-3226 if you have questions regarding comments on the financial
statements and related matters.
Sincerely,
Craig Wilson
Senior Assistant Chief
Accountant
??
??
??
??
Mr. Barry Steinberg
Manchester Technologies, Inc.
June 7, 2005
Page 2
</TEXT>
</DOCUMENT>