SEC Comment Letter for Stabilis Solutions, Inc. (SLNG) (CIK 0001043186) (SLNG) — Jan 5, 2010
Stabilis Solutions, Inc. (SLNG) (CIK 0001043186)
Date: Jan. 5, 2010 · CIK: 0001043186 · Accession: 0000000000-10-000463
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 15, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE January 5, 2010 Mr. John H. Untereker Sr. Vice President and CFO, Amer ican Electric Technologies, Inc. 6410 Long Drive Houston, TX 77087 Re: American Electric Technologies, Inc. Form 10-K for the year ended December 31, 2008 Form 10-Q for the quarter ended September 30, 2009 File No. 0-24575
Dear Mr. Untereker: We have reviewed your response to our letter dated December 15, 2009 and have the following comment. Where indicated, we think you should revise your disclosures in response to these comments. If you disagree, we will cons ider your explanation as to why our comment is inapplicable or a revision is unnecessary. Plea se understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may ha ve about our comments or on any other aspect of our review. Feel free to call us at the te lephone numbers listed at the end of this letter.
Form 10-K for the year ended December 31, 2008
11. Leases, page F-18
We note your response to our prior comment seve n and your disclosures in dicating that you lease certain facilities and equipment under operating lease agreements, prim arily related to the performance of service contracts. In future filin gs please, if these agreements are material, also include the future minimum rental payments requir ed as of the date of the latest balance sheet presented, in the aggregate and for each of the five succeeding fiscal years for your operating leases having initial or remaining noncancelable lease terms in excess of one year. Given your disclosures it appears that your operating lease expense may be mate rial to your results. Refer to ASC Topic 840.20.50.
Mr. John H. Untereker American Electric Technologies, Inc. January 5, 2010 Page 2
As appropriate, please amend your filing a nd respond to these comments within 10 business days or tell us when you will provide us with a response. Please provide us with a supplemental response letter that keys your re sponses to our comments and provides any requested supplemental information. Detailed letter s greatly facilitate our review. Please file your supplemental response on EDGAR as a corres pondence file. 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 Mindy Hooker, Staff Accountant, at (202) 551- 3732, or to the undersigned at (202) 551-3768.
Sincerely, John Cash Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
January 5, 2010
Mr. John H. Untereker Sr. Vice President and CFO, Amer ican Electric Technologies, Inc.
6410 Long Drive Houston, TX 77087
Re: American Electric Technologies, Inc.
Form 10-K for the year ended December 31, 2008 Form 10-Q for the quarter ended September 30, 2009
File No. 0-24575
Dear Mr. Untereker:
We have reviewed your response to our letter dated December 15, 2009 and have the
following comment. Where indicated, we think you should revise your disclosures in response
to these comments. If you disagree, we will cons ider your explanation as to why our comment is
inapplicable or a revision is unnecessary. Plea se understand that the purpose of our review
process is to assist you in your compliance with the applicable disclosure requirements and to
enhance the overall disclosure in your filing. We look forward to working with you in these
respects. We welcome any questions you may ha ve about our comments or on any other aspect
of our review. Feel free to call us at the te lephone numbers listed at the end of this letter.
Form 10-K for the year ended December 31, 2008
11. Leases, page F-18
We note your response to our prior comment seve n and your disclosures in dicating that you lease
certain facilities and equipment under operating lease agreements, prim arily related to the
performance of service contracts. In future filin gs please, if these agreements are material, also
include the future minimum rental payments requir ed as of the date of the latest balance sheet
presented, in the aggregate and for each of the five succeeding fiscal years for your operating leases having initial or remaining noncancelable lease terms in excess of one year. Given your
disclosures it appears that your operating lease expense may be mate rial to your results. Refer to
ASC Topic 840.20.50.
Mr. John H. Untereker
American Electric Technologies, Inc.
January 5, 2010 Page 2
As appropriate, please amend your filing a nd respond to these comments within 10
business days or tell us when you will provide us with a response. Please provide us with a
supplemental response letter that keys your re sponses to our comments and provides any
requested supplemental information. Detailed letter s greatly facilitate our review. Please file
your supplemental response on EDGAR as a corres pondence file. 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 Mindy
Hooker, Staff Accountant, at (202) 551- 3732, or to the undersigned at (202) 551-3768.
Sincerely, John Cash Branch Chief