SEC Comment Letter for GLOBAL DIVERSIFIED INDUSTRIES INC (CIK 0001090461) — Aug 12, 2005
GLOBAL DIVERSIFIED INDUSTRIES INC (CIK 0001090461)
Date: Aug. 12, 2005 · CIK: 0001090461 · Accession: 0000000000-05-041879
AI Filing Summary & Sentiment
File numbers found in text: 333-83231
Referenced dates: August 4, 2005
Letter
Mail Stop 4561 VIA U.S. MAIL AND FAX (559) 665-7066 Mr. Phil Hamilton President and Chief Executive Officer Global Diversified Industries, Inc. 1200 Airport Drive Chowchilla, CA 93610
Re: Global Diversified Industries, Inc. Form 10-KSB for the year ended April 30, 2004 Filed August 17, 2004 File No. 333-83231
Dear Mr. Hamilton:
We have reviewed your response letter dated August 4, 2005 and have the following additional comments. Feel free to call us at the telephone numbers listed at the end of this letter.
1. Based on our previous discussion and response to our prior comment letters, it does not appear that you have consistently applied either SAB 101 or SOP 81-1 in recognizing revenue. Please tell us whether you recognize revenue in accordance with SAB 101, as amended by SAB 104, or SOP 81-1 and your basis for doing so. In your response, please also show us the impact on your historical financial statements if you had consistently applied either SAB 101 or SOP 81- 1.
2. If your response to comment 1 results in a material change to your historical financial statements please revise your financial statements in response to this comment. Refer to SAB 99 (SAB Topic 1M).
3. If you account for your contracts under SOP 81-1 please tell us in sufficient detail how you plan to account for revenues and costs in accordance with SOP 81-1 under your revised accounting policy. In your response, please also tell us how considered and your basis for determining the following in accounting for your contracts under SOP 81-1:
a. Accounting policy decision to use the percentage-of-completion method or completed-contract method, including your application of paragraph 25 if you account for your contracts under the percentage- of-completion method;
b. Determining the profit center for revenue recognition, including consideration given to segmenting a contract (Refer to paragraphs 34- 42 of SOP 81-1);
c. Method used to measure the extent of progress toward completion (Refer to paragraphs 43-51 of SOP 81-1).
4. Please show us how you plan to revise your revenue recognition policy disclosure in future filings. Refer to APB 22.
* * * *
You may contact Josh Forgione, at (202) 551-3431, or me, at (202) 551-3403, if you have questions. Please respond to the comments included in this letter within 10 business days or tell us when you will provide us with a response. Please file your response on EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
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Show Raw Text
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<TEXT>
August 12, 2005
Mail Stop 4561
VIA U.S. MAIL AND FAX (559) 665-7066
Mr. Phil Hamilton
President and Chief Executive Officer
Global Diversified Industries, Inc.
1200 Airport Drive
Chowchilla, CA 93610
Re: Global Diversified Industries, Inc.
Form 10-KSB for the year ended April 30, 2004
Filed August 17, 2004
File No. 333-83231
Dear Mr. Hamilton:
We have reviewed your response letter dated August 4, 2005
and
have the following additional comments. Feel free to call us at
the
telephone numbers listed at the end of this letter.
1. Based on our previous discussion and response to our prior
comment
letters, it does not appear that you have consistently applied
either
SAB 101 or SOP 81-1 in recognizing revenue. Please tell us
whether
you recognize revenue in accordance with SAB 101, as amended by
SAB
104, or SOP 81-1 and your basis for doing so. In your response,
please also show us the impact on your historical financial
statements if you had consistently applied either SAB 101 or SOP
81-
1.
2. If your response to comment 1 results in a material change to
your
historical financial statements please revise your financial
statements in response to this comment. Refer to SAB 99 (SAB
Topic
1M).
3. If you account for your contracts under SOP 81-1 please tell us
in
sufficient detail how you plan to account for revenues and costs
in
accordance with SOP 81-1 under your revised accounting policy. In
your response, please also tell us how considered and your basis
for
determining the following in accounting for your contracts under
SOP
81-1:
a. Accounting policy decision to use the percentage-of-completion
method or completed-contract method, including your application of
paragraph 25 if you account for your contracts under the
percentage-
of-completion method;
b. Determining the profit center for revenue recognition,
including
consideration given to segmenting a contract (Refer to paragraphs
34-
42 of SOP 81-1);
c. Method used to measure the extent of progress toward completion
(Refer to paragraphs 43-51 of SOP 81-1).
4. Please show us how you plan to revise your revenue recognition
policy disclosure in future filings. Refer to APB 22.
* * * *
You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within 10 business days or tell us when
you
will provide us with a response. Please file your response on
EDGAR.
Sincerely,
Steven Jacobs
Accounting Branch Chief
??
??
??
??
Mr. Phil Hamilton
Global Diversified Industries, Inc.
August 12, 2005
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