SEC Company Response from INDUS REALTY TRUST, INC. (CIK 0001037390) — Aug 2, 2005
INDUS REALTY TRUST, INC. (CIK 0001037390)
Date: Aug. 2, 2005 · CIK: 0001037390 · Accession: 0001037390-05-000043
AI Filing Summary & Sentiment
Referenced dates: July 27, 2005
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Re: Griffin Land & Nurseries Inc. Item 4.02 Form 8-K Filed July 26, 2005 File No. 1-12879
Dear Ms. Shah:
This letter sets forth the response of Griffin Land & Nurseries Inc. (the “Company”) to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the above-referenced filing received by letter dated July 27, 2005. For your convenience, we have set forth the Staff’s comments immediately preceding our response.
Staff Comments:
We have reviewed your Item 4.02 Form 8-K for compliance with the form requirements.
We remind you that when you file your restated Form 10-K/A, you should appropriately address the following:
·
an explanatory paragraph in the reissued audit opinion,
·
full compliance with APB 20, paragraphs 36 and 37,
·
fully update all affected portions of the document, including MD&A, selected financial data, and quarterly financial data,
·
updated Item 9A disclosures should include the following:
o
a discussion of the restatement and the facts and circumstances surrounding it,
o
how the restatement impacted the CEO and CFO’s original conclusions regarding the effectiveness of their disclosure controls and procedures,
o
changes to internal controls over financial reporting, and
o
anticipated changes to disclosure controls and procedures and/or internal controls over financial reporting to prevent future misstatements of a similar nature.
Refer to Items 307 and 308(c) of Regulation S-K.
·
updated certifications.
Response:
The Company acknowledges the Staff’s comments and is evaluating them as part of its preparation of the restated Form 10-K/A.
* * * * *
Pursuant to your request, the Company acknowledges that: (i) it is responsible for the adequacy and accuracy of the disclosure in its filings; (ii) 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 (iii) 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.
If you have any questions or comments with respect to these responses or other matters, please call the undersigned at (212) 218-7910.
Very
truly yours,
/s/
Frederick M. Danziger
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Griffin
Land & Nurseries, Inc.
Griffin
Land & Nurseries, Inc.
One
Rockefeller Plaza
New
York, NY 10020
Phone:
(212) 218-7910
FAX:
(212) 218-7917
August
2,
2005
VIA
EDGAR
Nilimah
N. Shah
Accounting
Branch Chief
Division
of Corporation Finance
Securities
and Exchange Commission
100
F
Street, N.E., Mail Stop 7010
Washington,
D.C. 20549-7010
Re: Griffin
Land & Nurseries Inc.
Item
4.02 Form 8-K
Filed
July 26, 2005
File
No. 1-12879
Dear
Ms.
Shah:
This
letter sets forth the response of Griffin Land & Nurseries Inc. (the
“Company”) to the comments of the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) to the above-referenced filing received
by letter dated July 27, 2005. For your convenience, we have set forth the
Staff’s comments immediately preceding our response.
Staff
Comments:
We
have reviewed your Item 4.02 Form 8-K for compliance with the form
requirements.
We
remind you that when you file your restated Form 10-K/A, you should
appropriately address the following:
·
an
explanatory paragraph in the reissued audit
opinion,
·
full
compliance with APB 20, paragraphs 36 and
37,
·
fully
update all affected portions of the document, including MD&A, selected
financial data, and quarterly financial
data,
·
updated
Item 9A disclosures should include the
following:
o
a
discussion of the restatement and the facts and circumstances surrounding
it,
o
how
the restatement impacted the CEO and CFO’s original conclusions regarding
the effectiveness of their disclosure controls and
procedures,
o
changes
to internal controls over financial reporting,
and
o
anticipated
changes to disclosure controls and procedures and/or internal controls
over financial reporting to prevent future misstatements of a similar
nature.
Refer
to Items 307 and 308(c) of Regulation S-K.
·
updated
certifications.
Response:
The
Company acknowledges the Staff’s comments and is evaluating them as part of its
preparation of the restated Form 10-K/A.
*
* * *
*
Pursuant
to your request, the Company acknowledges that: (i) it is responsible for
the
adequacy and accuracy of the disclosure in its filings; (ii) 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 (iii) 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.
If
you
have any questions or comments with respect to these responses or other matters,
please call the undersigned at (212) 218-7910.
Very
truly yours,
/s/
Frederick M. Danziger
Frederick
M. Danziger
President,
Chief Executive Officer