SEC Comment Letter for RICEX CO (CIK 0001061881) — Nov 9, 2004
RICEX CO (CIK 0001061881)
Date: Nov. 9, 2004 · CIK: 0001061881 · Accession: 0000000000-04-035951
AI Filing Summary & Sentiment
Letter
<DESCRIPTION>COMMENT LETTER DATED 10/21/04 ON ITEM 4 8-K FILED 10/05/04 October 21, 2004 Via US Mail Mr. Terrence Barber, Chief Executive Officer The Ricex Company 1241 Hawk`s Flight Court El Dorado Hills, California 95762
RE: Form 8-K filed on October 5, 2004 The Ricex Company - File No. 0-24285
Dear Mr. Barber:
The staff has reviewed the above-referenced filing for compliance with the requirements of Form 8-K and has the following comments in that regard. Feel free to contact us at the number listed at the end of this letter. Please 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 have about our comments or on any other aspect of our review.
Reportable events
Refer to the paragraphs of the Form 8-K where you identify the accounting disagreement and please tell us in a supplemental letter:
1) what period the disagreement relates to, 2) the nature of the disagreement including the company`s position and the former accountant`s position at the time of the disagreement, 3) the amounts involved, 4) how the disagreement was resolved, 5) how and by whom any amounts were determined, and 6) whether or not you restated (or intend to restate) any prior period for any adjustment, and if not, why.
Please also note the requirements of Item 304(b) of Regulation S-K. If there were any material transactions or events similar to those involved in the disagreement that you accounted for or disclosed differently than your prior accountant would have concluded was required, you should provide all of the disclosures required by Item 304(b) of Regulation S-K.
Provide us with any letters or written communication to and from the former accountants regarding the disagreement and their resolution to management or the Audit Committee.
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.
General
Please file your supplemental response and amendment (if appropriate) via EDGAR in response to these comments within 5 business days of the date of this letter. Please note that if you require longer than 5 business days to respond, you should contact the staff immediately to request additional time. Direct any questions regarding the above to John A. Weitzel, Staff Accountant at (202) 942-1807.
Sincerely,
John A. Weitzel
Staff Accountant
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<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>ricex8kletter.txt
<DESCRIPTION>COMMENT LETTER DATED 10/21/04 ON ITEM 4 8-K FILED 10/05/04
<TEXT>
October 21, 2004
Via US Mail
Mr. Terrence Barber, Chief Executive Officer
The Ricex Company
1241 Hawk`s Flight Court
El Dorado Hills, California 95762
RE: Form 8-K filed on October 5, 2004
The Ricex Company - File No. 0-24285
Dear Mr. Barber:
The staff has reviewed the above-referenced filing for
compliance with the requirements of Form 8-K and has the following
comments in that regard. Feel free to contact us at the number
listed at the end of this letter. Please 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 have about our
comments or on any other aspect of our review.
Reportable events
Refer to the paragraphs of the Form 8-K where you identify the
accounting disagreement and please tell us in a supplemental letter:
1) what period the disagreement relates to,
2) the nature of the disagreement including the company`s position
and the former accountant`s position at the time of the disagreement,
3) the amounts involved,
4) how the disagreement was resolved,
5) how and by whom any amounts were determined, and
6) whether or not you restated (or intend to restate) any prior
period for any adjustment, and if not, why.
Please also note the requirements of Item 304(b) of Regulation S-K.
If there were any material transactions or events similar to those
involved in the disagreement that you accounted for or disclosed
differently than your prior accountant would have concluded was
required, you should provide all of the disclosures required by Item
304(b) of Regulation S-K.
Provide us with any letters or written communication to and from the
former accountants regarding the disagreement and their resolution to
management or the Audit Committee.
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.
General
Please file your supplemental response and amendment (if appropriate)
via EDGAR in response to these comments within 5 business days of the
date of this letter. Please note that if you require longer than 5
business days to respond, you should contact the staff immediately to
request additional time. Direct any questions regarding the above to
John A. Weitzel, Staff Accountant at (202) 942-1807.
Sincerely,
John A. Weitzel
Staff Accountant
Mr. Terrence Barber
The Ricex Company
October 21, 2004
Page 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
</TEXT>
</DOCUMENT>