SEC Comment Letter for INDUSTRIAL DISTRIBUTION GROUP INC (CIK 0001042351) — Apr 22, 2005
INDUSTRIAL DISTRIBUTION GROUP INC (CIK 0001042351)
Date: April 22, 2005 · CIK: 0001042351 · Accession: 0000000000-05-019899
AI Filing Summary & Sentiment
File numbers found in text: 001-13195
Referenced dates: April 18, 2005
Letter
April 22, 2005 By U.S. Mail and facsimile to (404)949-2040 Mr. Jack P. Healey Industrial Distribution Group, Inc. Senior Vice President and Chief Financial Officer 950 East Paces Ferry Road, Suite 1575 Atlanta, Georgia 30326
Re: Industrial Distribution Group, Inc. Form 10-K for the year ended December 31, 2004 File No. 001-13195
Dear Mr. Healey:
We have reviewed your response letter dated April 18, 2005 and have the following additional comments. If you disagree, we will consider your explanation as to why our comment is inapplicable. 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 or may not raise additional comments.
FORM 10-K FOR THE PERIOD ENDED DECEMBER 31, 2004
1. We note your response to our prior comment eight. Please consider revising your disclosure in your business section and management`s discussion and analysis to better describe the actual activity of your service revenue. The disclosure as it currently stands may indicate to a reader that service revenue is a more material aspect of the business than it actually is. Supplementally, confirm to us your intentions in this regard.
* * * *
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please direct them to Patricia Armelin, Staff Accountant, at (202) 824- 5563, Nathan Cheney at (202) 942-1804 or, in their absence, to the undersigned at (202) 824-5373.
Sincerely,
John Cash
Accounting Branch Chief
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<TEXT>
Mail Stop 0510
April 22, 2005
By U.S. Mail and facsimile to (404)949-2040
Mr. Jack P. Healey
Industrial Distribution Group, Inc.
Senior Vice President and Chief Financial Officer
950 East Paces Ferry Road, Suite 1575
Atlanta, Georgia 30326
Re: Industrial Distribution Group, Inc.
Form 10-K for the year ended December 31, 2004
File No. 001-13195
Dear Mr. Healey:
We have reviewed your response letter dated April 18, 2005
and
have the following additional comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable.
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 or may not raise additional
comments.
FORM 10-K FOR THE PERIOD ENDED DECEMBER 31, 2004
1. We note your response to our prior comment eight. Please
consider
revising your disclosure in your business section and management`s
discussion and analysis to better describe the actual activity of
your service revenue. The disclosure as it currently stands may
indicate to a reader that service revenue is a more material
aspect
of the business than it actually is. Supplementally, confirm to
us
your intentions in this regard.
* * * *
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information. Detailed
response
letters greatly facilitate our review. Please file your response
letter on EDGAR. Please understand that we may have additional
comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please
direct them to Patricia Armelin, Staff Accountant, at (202) 824-
5563,
Nathan Cheney at (202) 942-1804 or, in their absence, to the
undersigned at (202) 824-5373.
Sincerely,
John Cash
Accounting Branch Chief
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Mr. Jack P. Healey
April 22, 2005
Page 1 of 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510
DIVISION OF
CORPORATION FINANCE
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