SEC Comment Letter for GLOBAL DIVERSIFIED INDUSTRIES INC (CIK 0001090461) — Sep 19, 2005
GLOBAL DIVERSIFIED INDUSTRIES INC (CIK 0001090461)
Date: Sept. 19, 2005 · CIK: 0001090461 · Accession: 0000000000-05-048169
AI Filing Summary & Sentiment
File numbers found in text: 333-83231
Referenced dates: August 25, 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 25, 2005 and have the following additional comments. Feel free to call us at the telephone numbers listed at the end of this letter.
1. We note from your response to comment 1 that your customer has the option to hire other contractors or use in-house staff to perform delivery and installation services. If you are contractually obligated to perform installation services with respect to bill and hold arrangements as of April 30, 2005, please further explain to us how you considered the fifth criteria in SAB Topic 13(A)(3)(a).
2. Please tell us how and when you recognize revenue for installation services related to your bill and hold arrangements. In addition, please tell us whether you consider the installation services to be a separate unit of accounting under EITF 00-21. If so, please tell us how you meet each of the criteria in paragraph 9 of EITF 00-21. Refer to paragraph 16 of EITF 00-21 for the criteria of VSOE of fair value. Finally, please disclose your accounting policy, as required by paragraph 18 of EITF 00-21, in future filings.
* * * *
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
??
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
September 19, 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 25, 2005
and
have the following additional comments. Feel free to call us at
the
telephone numbers listed at the end of this letter.
1. We note from your response to comment 1 that your customer has
the
option to hire other contractors or use in-house staff to perform
delivery and installation services. If you are contractually
obligated to perform installation services with respect to bill
and
hold arrangements as of April 30, 2005, please further explain to
us
how you considered the fifth criteria in SAB Topic 13(A)(3)(a).
2. Please tell us how and when you recognize revenue for
installation
services related to your bill and hold arrangements. In addition,
please tell us whether you consider the installation services to
be a
separate unit of accounting under EITF 00-21. If so, please tell
us
how you meet each of the criteria in paragraph 9 of EITF 00-21.
Refer to paragraph 16 of EITF 00-21 for the criteria of VSOE of
fair
value. Finally, please disclose your accounting policy, as
required
by paragraph 18 of EITF 00-21, in future filings.
* * * *
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.
September 19, 2005
Page 1
</TEXT>
</DOCUMENT>