SEC Company Response from INDUS REALTY TRUST, INC. (CIK 0001037390) — Dec 20, 2005
INDUS REALTY TRUST, INC. (CIK 0001037390)
Date: Dec. 20, 2005 · CIK: 0001037390 · Accession: 0001037390-05-000057
AI Filing Summary & Sentiment
Referenced dates: December 19, 2005, November 30, 2005, October 20, 2005
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Form 10-Q/A for the Fiscal Quarter Ended February 26, 2005 Forms 10-Q for the Fiscal Quarters Ended May 28, 2005 and August 27, Filed November 3, 2005 File No. 1-12879
Dear Ms. Shah:
This letter sets forth the response of Griffin Land & Nurseries, Inc. (the “Company”) to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the above-referenced filings received by letter dated December 19, 2005. For your convenience, we have set forth the Staff’s comment immediately preceding our response.
Staff Comment:
1.
Form 10-K/A for the Fiscal Year Ended November 27,
We have read your response to our comment 1 from our letter dated November 30, 2005. As previously communicated in our letters dated October 20, 2005 and November 30, 2005, your selected financial data for unaudited periods should be clearly marked as such. From your statement that “the selected financial data for fiscal 2002, fiscal 2003, and fiscal 2004 are derived from the audited restated consolidated financial statements included in Item 8 of this report,” it is unclear that fiscal 2001 and fiscal 2000 are derived from unaudited restated consolidated financial statements. Accordingly, in future filings, please revise your disclosures to clearly indicate that your selected financial data for fiscal 2001 are derived from unaudited restated consolidated financial statements.
Response:
The Company acknowledges the Staff’s comment and will incorporate such comment in preparing future filings.
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 filings; 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 (860) 653-4541, ext. 125.
Very
truly yours,
/s/
Anthony J. Galici
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CORRESP
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filename1.htm
Response to letter of December 19
Griffin
Land & Nurseries, Inc.
90
Salmon Brook Street
Granby,
Ct 06035
(860)
653-4541
(860)
653-2919 (fax)
December
20, 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.
Form
10-K/A for the Fiscal Year Ended November 27, 2004
Form
10-Q/A for the Fiscal Quarter Ended February 26, 2005
Forms
10-Q for the Fiscal Quarters Ended May 28, 2005 and August 27,
2005
Filed
November 3, 2005
File
No. 1-12879
Dear
Ms.
Shah:
This
letter sets forth the response of Griffin Land & Nurseries, Inc. (the
“Company”) to the comment of the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) to the above-referenced filings received
by letter dated December 19, 2005. For your convenience, we have set forth
the
Staff’s comment immediately preceding our response.
Staff
Comment:
1.
Form
10-K/A for the Fiscal Year Ended November 27,
2004
We
have
read your response to our comment 1 from our letter dated November 30, 2005.
As
previously communicated in our letters dated October 20, 2005 and November
30,
2005, your selected financial data for unaudited periods should be clearly
marked as such. From your statement that “the selected financial data for fiscal
2002, fiscal 2003, and fiscal 2004 are derived from the audited restated
consolidated financial statements included in Item 8 of this report,” it is
unclear that fiscal 2001 and fiscal 2000 are derived from unaudited restated
consolidated financial statements. Accordingly, in future filings, please revise
your disclosures to clearly indicate that your selected financial data for
fiscal 2001 are derived from unaudited restated consolidated financial
statements.
Response:
The
Company acknowledges the Staff’s comment and will incorporate such comment in
preparing future filings.
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 filings; 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 (860) 653-4541, ext. 125.
Very
truly yours,
/s/
Anthony J. Galici
Anthony
J. Galici
Vice
President, Chief Financial Officer
and
Secretary