SEC Company Response from MPW INDUSTRIAL SERVICES GROUP INC (CIK 0001047098) — Sep 28, 2004
MPW INDUSTRIAL SERVICES GROUP INC (CIK 0001047098)
Date: Sept. 28, 2004 · CIK: 0001047098 · Accession: 0001193125-04-163193
AI Filing Summary & Sentiment
Letter
Securities and Exchange Commission Washington, D.C. 20549 Re: MPW Industrial Services Group, Inc. Item 4.01, Form 8-K filed September 20, 2004 File No. 0-23335
Dear Ms. Luckey:
Set forth below are the responses of MPW Industrial Services Group, Inc. (the “Company” or “MPW”) to the comment letter of the staff of the United States Securities and Exchange Commission (the “SEC”) dated September 23, 2004 regarding MPW’s Form 8-K, filed September 20, 2004.
1. Please revise the Form to state whether the former accountant resigned, declined to stand for re-election or was dismissed, and the specific date, as required by Item 304(a)(1)(i) of Regulation S-K. It is not sufficient to state that the company “determined not to renew the engagement” of the accountant, as that wording is unclear to a reader.
Company Response: Item 9 of the Company’s Form 10-K, which was filed on September 24, 2004, indicated that Ernst & Young LLP was dismissed.
2. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your revised Form 8-K.
Company Response: An updated Exhibit 16 letter from Ernst & Young LLP was filed with the Company’s Form 10-K.
The Company is responsible for the adequacy and accuracy of the disclosure in the filings. Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing. 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.
Please do not hesitate to contact the undersigned at (800) 892-5195 with any questions or comments regarding any of the foregoing.
Very Truly Yours,
/s/ Robert Valentine
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CORRESP 1 dcorresp.htm CORRESPONDENCE Correspondence September 28, 2004 VIA OVERNIGHT CARRIER & EDGAR Ms. Cicely D. Luckey Senior Staff Accountant Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: MPW Industrial Services Group, Inc. Item 4.01, Form 8-K filed September 20, 2004 File No. 0-23335 Dear Ms. Luckey: Set forth below are the responses of MPW Industrial Services Group, Inc. (the “Company” or “MPW”) to the comment letter of the staff of the United States Securities and Exchange Commission (the “SEC”) dated September 23, 2004 regarding MPW’s Form 8-K, filed September 20, 2004. 1. Please revise the Form to state whether the former accountant resigned, declined to stand for re-election or was dismissed, and the specific date, as required by Item 304(a)(1)(i) of Regulation S-K. It is not sufficient to state that the company “determined not to renew the engagement” of the accountant, as that wording is unclear to a reader. Company Response: Item 9 of the Company’s Form 10-K, which was filed on September 24, 2004, indicated that Ernst & Young LLP was dismissed. 2. To the extent that you make changes to the Form 8-K to comply with our comments, please obtain and file an updated Exhibit 16 letter from the former accountants stating whether the accountant agrees with the statements made in your revised Form 8-K. Company Response: An updated Exhibit 16 letter from Ernst & Young LLP was filed with the Company’s Form 10-K. The Company is responsible for the adequacy and accuracy of the disclosure in the filings. Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing. 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. Please do not hesitate to contact the undersigned at (800) 892-5195 with any questions or comments regarding any of the foregoing. Very Truly Yours, /s/ Robert Valentine Robert Valentine Vice President, Chief Operating Officer, Chief Financial Officer, Secretary and Treasurer cc: M. Black – MPW T. Powers – Ernst & Young LLP R. Robins – Vorys, Sater, Seymour and Pease, LLP