SEC Company Response from GENERAL BEARING CORP (CIK 0001026221) — Oct 13, 2004
GENERAL BEARING CORP (CIK 0001026221)
Date: Oct. 13, 2004 · CIK: 0001026221 · Accession: 0001193805-04-001575
AI Filing Summary & Sentiment
Referenced dates: October 6, 2004
Letter
October 13, 2004 United States Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549-0510 Attn: Ms. Tracy Houser Staff Accountant
RE: General Bearing Corporation Form 8-K Item 4.01 filed October 5, 2004 File No. 0-22053
Dear Ms. Houser:
On behalf of General Bearing Corporation (the "Company"), set forth below are responses to your letter dated October 6, 2004.
Comment # 1
Please amend your Item 4.01, Form 8-K for the following:
o The specific date Urbach Kahn & Werlin LLP resigned as your independent auditors, as required by Item 304 (a) (1) (i) of Regulation S-K.
o The two fiscal years (i.e., fiscal years ended January 3, 2004 and December 28, 2002) in which you refer to in your disclosure required under Item 304 (a) (1) (ii) of Regulation S-K.
o The two fiscal years and the subsequent interim period (i.e., fiscal years ended January 3, 2004 and December 28, 2002 and January 4, 2004 through October 4, 2004) in which you refer to in your disclosure required under Item 304 (a) (1) (iv) of Regulation S-K.
We have amended Form 8-K to comply with your comments.
Comment # 2
To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your amended Form 8-K.
We have included the updated Exhibit 16 letter from the former accountants in the Company's amended Form 8-K.
Closing Comments:
Pursuant to your comments, the Company acknowledges that a) it is responsible for the adequacy and accuracy of the disclosure filings; b) staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and c) 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.
Pursuant to your request, we will file this response letter on EDGAR.
If you have any questions or require additional information, please call me at 845-358-6000 or fax me at 845-358-6277.
Respectfully yours,
/s/ David Gussack
-----------------------
David Gussack
Chief Executive Officer
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<DESCRIPTION>CORRESPONDENCE LETTER
<TEXT>
October 13, 2004
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0510
Attn: Ms. Tracy Houser
Staff Accountant
RE: General Bearing Corporation
Form 8-K Item 4.01 filed October 5, 2004
File No. 0-22053
Dear Ms. Houser:
On behalf of General Bearing Corporation (the "Company"), set forth below are
responses to your letter dated October 6, 2004.
Comment # 1
Please amend your Item 4.01, Form 8-K for the following:
o The specific date Urbach Kahn & Werlin LLP resigned as your independent
auditors, as required by Item 304 (a) (1) (i) of Regulation S-K.
o The two fiscal years (i.e., fiscal years ended January 3, 2004 and
December 28, 2002) in which you refer to in your disclosure required under
Item 304 (a) (1) (ii) of Regulation S-K.
o The two fiscal years and the subsequent interim period (i.e., fiscal years
ended January 3, 2004 and December 28, 2002 and January 4, 2004 through
October 4, 2004) in which you refer to in your disclosure required under
Item 304 (a) (1) (iv) of Regulation S-K.
We have amended Form 8-K to comply with your comments.
Comment # 2
To the extent that you make changes to the Form 8-K to comply with our comments,
please obtain and file an updated Exhibit 16 letter from the former accountants
stating whether the accountant agrees with the statements made in your amended
Form 8-K.
We have included the updated Exhibit 16 letter from the former accountants in
the Company's amended Form 8-K.
Closing Comments:
Pursuant to your comments, the Company acknowledges that a) it is responsible
for the adequacy and accuracy of the disclosure filings; b) staff comments or
changes to disclosure in response to staff comments in the filings reviewed by
the staff do not foreclose the Commission from taking any action with respect to
the filing; and c) 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.
Pursuant to your request, we will file this response letter on EDGAR.
If you have any questions or require additional information, please call me at
845-358-6000 or fax me at 845-358-6277.
Respectfully yours,
/s/ David Gussack
-----------------------
David Gussack
Chief Executive Officer
</TEXT>
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