SEC Comment Letter for Stabilis Solutions, Inc. (SLNG) (CIK 0001043186) (SLNG) — Nov 7, 2013
Stabilis Solutions, Inc. (SLNG) (CIK 0001043186)
Date: Nov. 7, 2013 · CIK: 0001043186 · Accession: 0000000000-13-061373
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE November 7 , 2013 Via E -mail Mr. Andrew Puhala Senior Vice President and Chief Financial Officer American Electric Technologies, Inc. 6410 Long Drive Houston, Texas 77087
Re: American Electric Technologies, Inc. Form 10 -K for the fis cal year ended December 31, 2012 Filed March 28, 2013 File No. 000 -24575
Dear Mr. Puhala :
We have reviewed your correspondence dated October 25, 2013 and have the following comments .
Please respond to this letter within ten busine ss days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances , please tell us why in your response.
After reviewing the information you pr ovide in response to these comments, we may have additional comments.
Form 10 -K for t he Fiscal Year Ended December 31 , 2012
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Foreign Joint Ventures, page 15
1. We note your response to our prior comment 2 but it continues to be unclear to us how you considered providing separate full equity method investee financial statements for BOMAY given that income from that investment was material to the company’s results a nd therefore would likely be material to an investor’s understanding of the underlying reasons for the company’s results. Please further explain to us why you do not believe that separate financial statements of
Andrew Puhala American Electric Technologies, Inc. November 7 , 2013 Page 2
BOMAY would be meaningful to an investor’s understanding of your operating results.
2. In future filings, given the significant contribution of the foreign joint ventures – especially BOMAY - to your results, please provide a robust discussion of the operating results of each of your significant foreign joint ventures in each period. For e xample, explain the underlying reasons for the significant increase in BOMAY’s gross sales, gross profit and net income in fiscal 2012 compared to the prior year.
You may contact Praveen Karthol y at (202) 551 -3778 or me at (202) 551 -3676 if you have questions regarding comments on the financial statements and related matters. You may also contact Martin James, Senior Assistant Chief Accountant, at (202) 551 - 3671 with any other questions.
Sincerely,
/s/ Brian Cascio
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
November 7 , 2013
Via E -mail
Mr. Andrew Puhala
Senior Vice President and Chief Financial Officer
American Electric Technologies, Inc.
6410 Long Drive
Houston, Texas 77087
Re: American Electric Technologies, Inc.
Form 10 -K for the fis cal year ended December 31, 2012
Filed March 28, 2013
File No. 000 -24575
Dear Mr. Puhala :
We have reviewed your correspondence dated October 25, 2013 and have the
following comments .
Please respond to this letter within ten busine ss days by providing the requested
information, or by advising us when you will provide the requested response. If you do
not believe our comments apply to your facts and circumstances , please tell us why in
your response.
After reviewing the information you pr ovide in response to these comments, we
may have additional comments.
Form 10 -K for t he Fiscal Year Ended December 31 , 2012
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Foreign Joint Ventures, page 15
1. We note your response to our prior comment 2 but it continues to be unclear to us
how you considered providing separate full equity method investee financial
statements for BOMAY given that income from that investment was material to
the company’s results a nd therefore would likely be material to an investor’s
understanding of the underlying reasons for the company’s results. Please further
explain to us why you do not believe that separate financial statements of
Andrew Puhala
American Electric Technologies, Inc.
November 7 , 2013
Page 2
BOMAY would be meaningful to an investor’s understanding of your operating
results.
2. In future filings, given the significant contribution of the foreign joint ventures –
especially BOMAY - to your results, please provide a robust discussion of the
operating results of each of your significant foreign joint ventures in each
period. For e xample, explain the underlying reasons for the significant increase in
BOMAY’s gross sales, gross profit and net income in fiscal 2012 compared to the
prior year.
You may contact Praveen Karthol y at (202) 551 -3778 or me at (202) 551 -3676 if
you have questions regarding comments on the financial statements and related matters.
You may also contact Martin James, Senior Assistant Chief Accountant, at (202) 551 -
3671 with any other questions.
Sincerely,
/s/ Brian Cascio
Brian Cascio
Accounting Branch Chie f