SEC Company Response from INDUSTRIAL DISTRIBUTION GROUP INC (CIK 0001042351) — May 6, 2005
INDUSTRIAL DISTRIBUTION GROUP INC (CIK 0001042351)
Date: May 6, 2005 · CIK: 0001042351 · Accession: 0001167966-05-000688
AI Filing Summary & Sentiment
Referenced dates: April 22, 2005
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporate Finance Washington, DC 20549 Attention: John Cash, Accounting Branch Chief Re: Response to the Staff’s Follow-up Comment on Industrial Distribution Group, Inc., Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2004, File No. 1-13195.
Dear Sirs:
At the request and on behalf of our client, Industrial Distribution Group, Inc. (“IDG” or the “Company”), we provide below the Company’s response to the Staff’s follow-up comment in its letter dated April 22, 2005, with respect to the Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2004. A copy of this letter is being sent to the Staff by overnight delivery.
Comment:
We note your responses 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.
Response:
We will consider revisions as requested by the Staff to our narrative disclosures in the business and MD&A sections of our future filings.
Securities and Exchange Commission
Attn: John Cash, Accounting Branch Chief
May 5,
Page
In making such revisions, we will ensure that investors have the information necessary to distinguish between our service revenue activity and our overall FPS sales activities. Our FPS sales activities, as reflected in our current disclosures, are part of our principal strategic focus, and we expect to continue to highlight that focus in our future disclosures. In doing so, however, we will point out more clearly that our revenue for services activity - whether or not a part of our overall FPS sales strategy - is not the principal or a material focus of our operations or business strategy.
The Staff is requested to direct any questions regarding the response made in this letter to the undersigned at (404) 815-6587 or to Michael Coppock at (404) 815-6238.
Thank you very much for your consideration in this matter.
Very
truly yours,
/s/
W. Randy Eaddy
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filename1.htm
Response to the Staff's Follow-up comment
Suite
2800 1100 Peachtree St.
Atlanta
GA 30309-4530
t
404 815 6500 f 404 815 6555
www.KilpatrickStockton.com
May
5, 2005
direct
dial 404
815 6587
direct
fax 404 541 3186
REaddy@KilpatrickStockton.com
VIA
EDGAR
COPY
VIA UPS
Securities
and Exchange Commission
Division
of Corporate Finance
450 Fifth
Street, NW
Washington,
DC 20549
Attention:
John Cash, Accounting Branch Chief
Re:
Response
to the Staff’s Follow-up Comment on Industrial Distribution Group, Inc.,
Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2004,
File No. 1-13195.
Dear
Sirs:
At the
request and on behalf of our client, Industrial Distribution Group, Inc. (“IDG”
or the “Company”), we provide below the Company’s response to the Staff’s
follow-up comment in its letter dated April 22, 2005, with respect to the Annual
Report on Form 10-K for the Fiscal Year Ended December 31, 2004. A copy of this
letter is being sent to the Staff by overnight delivery.
Comment:
We
note your responses 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.
Response:
We
will consider revisions as requested by the Staff to our narrative
disclosures in the business and MD&A sections of our future
filings.
Securities
and Exchange Commission
Attn:
John Cash, Accounting Branch Chief
May 5,
2005
Page
2
In
making such revisions, we will ensure that investors have the information
necessary to distinguish between our service revenue activity and our
overall FPS sales activities. Our FPS sales activities, as reflected in
our current disclosures, are part of our principal strategic focus, and we
expect to continue to highlight that focus in our future disclosures. In
doing so, however, we will point out more clearly that our revenue for
services activity - whether or not a part of our overall FPS sales
strategy - is not the principal or a material focus of our operations or
business strategy.
The Staff
is requested to direct any questions regarding the response made in this letter
to the undersigned at (404) 815-6587 or to Michael Coppock at (404)
815-6238.
Thank you
very much for your consideration in this matter.
Very
truly yours,
/s/
W. Randy Eaddy
W.
Randy Eaddy
Cc:
Mr.
Jack P. Healey
Senior
Vice President and
Chief
Financial Officer
Industrial
Distribution Group, Inc
Michael B. Coppock, Esq
.
.