SEC Comment Letter for Bimergen Energy Corp (BESS, BESS-WT) (CIK 0001066764) (BESS) — Jan 21, 2011
Bimergen Energy Corp (BESS, BESS-WT) (CIK 0001066764)
Date: Jan. 21, 2011 · CIK: 0001066764 · Accession: 0000000000-11-004349
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-27407
Letter
January 21, 2011 William F. Donovan, M.D. Chief Executive Officer Spine Pain Management, Inc. 5225 Katy Freeway Suite 600 Houston, Texas 77007 Re: Spine Pain Management, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 31, 2010 Form 10-Q for the Quarterly Period ended June 30, 2010 Filed August 16, 2010 File No. 000-27407
Dear Dr. Donovan: We have reviewed your December 8, 2010 resp onse to our November 24, 2010 letter and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised disclosure will look like and identify the annual or quarterly filing, as applicable, in which you intend to first include it. If you do not believe the comment applies to your facts and circumstances, please tell us why in your res ponse. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your responses to our comments. After reviewing the information provided, we may have additional comments and/or request that you amend your filing. Form 10-K for the Fiscal Year Ended December 31, 2009
Item 7. Management’s Discussion and Analys is of Financial Condition and Results of Operations Critical Accounting Policies Revenue Recognition, page 20
1. Refer to Comment three. It remains unc lear why gross revenue presentation is appropriate as the amount billed does not represent the amount you expect to be
William F. Donovan, M.D. Spine Pain Management, Inc. January 21, 2011 Page 2
collected. Please revise your presentati on to only present net revenue, which was $540,505 in 2009, or tell us why the current presen tation is appropriate. This does not prohibit you from providing a discussion of your contractual allowanc e in your notes to the financial statements and/or in MD&A.
Please contact James Peklenk, Staff Account ant, at (202) 551-3661 or Joel Parker, Accounting Branch Chief, at (202) 551-3651 if you have any questions regarding the comments. In this regard, do not hesitate to contact me, at (202) 551-3679.
Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant
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January 21, 2011 William F. Donovan, M.D. Chief Executive Officer Spine Pain Management, Inc. 5225 Katy Freeway Suite 600 Houston, Texas 77007 Re: Spine Pain Management, Inc. Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 31, 2010 Form 10-Q for the Quarterly Period ended June 30, 2010 Filed August 16, 2010 File No. 000-27407 Dear Dr. Donovan: We have reviewed your December 8, 2010 resp onse to our November 24, 2010 letter and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised disclosure will look like and identify the annual or quarterly filing, as applicable, in which you intend to first include it. If you do not believe the comment applies to your facts and circumstances, please tell us why in your res ponse. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your responses to our comments. After reviewing the information provided, we may have additional comments and/or request that you amend your filing. Form 10-K for the Fiscal Year Ended December 31, 2009 Item 7. Management’s Discussion and Analys is of Financial Condition and Results of Operations Critical Accounting Policies Revenue Recognition, page 20 1. Refer to Comment three. It remains unc lear why gross revenue presentation is appropriate as the amount billed does not represent the amount you expect to be William F. Donovan, M.D. Spine Pain Management, Inc. January 21, 2011 Page 2 collected. Please revise your presentati on to only present net revenue, which was $540,505 in 2009, or tell us why the current presen tation is appropriate. This does not prohibit you from providing a discussion of your contractual allowanc e in your notes to the financial statements and/or in MD&A. Please contact James Peklenk, Staff Account ant, at (202) 551-3661 or Joel Parker, Accounting Branch Chief, at (202) 551-3651 if you have any questions regarding the comments. In this regard, do not hesitate to contact me, at (202) 551-3679. Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant