SEC Comment Letter for VASCULAR SOLUTIONS INC (CIK 0001030206) — Oct 5, 2004
VASCULAR SOLUTIONS INC (CIK 0001030206)
Date: Oct. 5, 2004 · CIK: 0001030206 · Accession: 0000000000-04-031862
AI Filing Summary & Sentiment
Letter
October 5, 2004 Mail Stop 3-6 James Hennen, CFO Vascular Solutions, Inc. 6464 Sycamore Court Minneapolis, MN 55369
Re: Vascular Solutions, Inc File No. 0-27605 Form 8-K, filed October 1, 2004
Dear Mr. Hennen:
We have reviewed the above referenced filing and have the following comments.
After Ernst & Young has completed their review of the Form 10-Q for the quarter ending September 30, 2004 and their engagement with the Company is finalized an amendment to this 8-K should be filed. The disclosures required by Item 304(a)(1)(iv) & (v) should be provided to cover the periods up to and including the date the association with E&Y is finalized.
A letter from the former accountants stating their agreement/disagreement with the revised disclosures should be included in the amendment as Exhibit 16. The amendment should be filed in response to these comments within 5 business days of the date E & Y`s association with the Company is finalized.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 filings;
* Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do n0t 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.
Questions with regard to this letter may be addressed to the undersigned at (202) 942-1897.
Sincerely,
Louis M. Canant
Senior Staff Accountant
Office of Electronics and Machinery
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<DOCUMENT> <TYPE>LETTER <SEQUENCE>1 <FILENAME>upload.txt <DESCRIPTION>ACCT LTR: L.M. CANANT ITEM 4 8-K FILED 10-1-04 <TEXT> October 5, 2004 Mail Stop 3-6 James Hennen, CFO Vascular Solutions, Inc. 6464 Sycamore Court Minneapolis, MN 55369 Re: Vascular Solutions, Inc File No. 0-27605 Form 8-K, filed October 1, 2004 Dear Mr. Hennen: We have reviewed the above referenced filing and have the following comments. After Ernst & Young has completed their review of the Form 10-Q for the quarter ending September 30, 2004 and their engagement with the Company is finalized an amendment to this 8-K should be filed. The disclosures required by Item 304(a)(1)(iv) & (v) should be provided to cover the periods up to and including the date the association with E&Y is finalized. A letter from the former accountants stating their agreement/disagreement with the revised disclosures should be included in the amendment as Exhibit 16. The amendment should be filed in response to these comments within 5 business days of the date E & Y`s association with the Company is finalized. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 filings; * Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do n0t 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. Questions with regard to this letter may be addressed to the undersigned at (202) 942-1897. Sincerely, Louis M. Canant Senior Staff Accountant Office of Electronics and Machinery ?? James Hennen, CFO Vascular Solutions, Inc </TEXT> </DOCUMENT>