SEC Comment Letter for NEWPORT INTERNATIONAL GROUP INC (CIK 0001103577) — Sep 28, 2005
NEWPORT INTERNATIONAL GROUP INC (CIK 0001103577)
Date: Sept. 28, 2005 · CIK: 0001103577 · Accession: 0000000000-05-050078
AI Filing Summary & Sentiment
File numbers found in text: 000-30587
Referenced dates: July 28, 2005, June 29, 2005
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<TYPE>LETTER
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<FILENAME>filename1.txt
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September 6, 2005
Mail Stop 4561
Mr. Cery Perle
Chief Executive Officer
Newport International Group, Inc.
73061 El Paseo Road, Suite 202
Palm Desert, CA 92260
Re: Newport International Group, Inc.
Form 10-KSB for the year ended December 31, 2004
Forms 10-Q for the quarters ended March 31 and June 30,
2005
Filed 4/1/05
File No. 000-30587
Dear Mr. Perle:
We have reviewed your response letter dated July 28, 2005
and
have the following additional comments. As previously stated,
these
comments require amendment to the referenced filings previously
filed
with the Commission.
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. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-KSB for the year ended December 31, 2004
Consolidated Balance Sheet, page F-3
1. We note your response to comment 1 and would not object to the
exclusion of the call option on your balance sheet due to
materiality. However, it appears that the escrowed shares of
Langley
Park should be recorded as a restricted asset rather than as a
contra-equity account. Please amend your financial statements
accordingly.
Consolidated Statements of Operations, page F-4
2. We note that your investment in the Langley Park shares was
reclassified from available-for-sale to trading securities in the
quarter ended June 30, 2005 and subsequently sold in July 2005.
In
light of these circumstances, it appears that you may not have had
the intent or ability to hold the securities for a sufficient
length
of time to allow for a recovery in market value as was represented
to
us in your letter dated June 29, 2005. Please revise your
financial
statements for the year ended December 31, 2004 to recognize the
impairment related to your Langley Park investment into earnings
or
advise us why a revision is unnecessary. Reference is made to
paragraph 15 of SFAS 115.
* * * *
As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response. You may wish to provide us with marked copies of
the amendment to expedite our review. Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information. Detailed cover
letters greatly facilitate our review. Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision. Since the company and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.
You may contact Kristi Beshears at (202) 551-3429 or me at
(202) 551-3486 if you have questions.
Sincerely,
Daniel L. Gordon
Branch Chief
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Newport International Group, Inc.
September 6, 2005
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