SEC Comment Letter for ARDEN REALTY LIMITED PARTNERSHIP (CIK 0001111853) — Apr 14, 2005
ARDEN REALTY LIMITED PARTNERSHIP (CIK 0001111853)
Date: April 14, 2005 · CIK: 0001111853 · Accession: 0000000000-05-018150
AI Filing Summary & Sentiment
Letter
Mail Stop 04-09 VIA U.S. MAIL AND FAX 1-310-966-9494 Victor J. Coleman President, Chief Operating Officer and Director Arden Realty Limited Partnership 11601 Wilshire Boulevard, Fourth Floor Los Angeles, CA 90025
RE: Arden Realty Limited Partnership Form 10-K for the year ended December 31, 2004
Dear Mr. Coleman:
We have reviewed the above referenced filings and have the following comments. We have limited our review to only your financial statements and related disclosures and will make no further review of your documents. As such, all persons who are responsible for the adequacy and accuracy of the disclosure are urged to be certain that they have included all information required pursuant to the Securities Exchange Act of 1934.
Where indicated, we think you should revise your documents in response to these comments in future filings. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
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-K fiscal year ended December 31, 2004
Consolidated Statements of Income, page F-3 1. What is your basis in GAAP for presenting income from continuing operations before impairment on investment in securities and how does your presentation comply with Rule 5-03 of Regulation S-X and Item 10(e) of Regulation S-K? Prior to the impairment, where did you record any income / loss related to this investment?
Exhibit 12.1 2. How did you consider the guidance in Item 5-03(d)(1)(c) of Regulation S-K when including the results of discontinued operations within your calculation of ratio of earnings to fixed charges?
* * * *
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a cover letter with your proposed revisions that keys your responses to our comments and provides any requested supplemental information. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain 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.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that
* the company is responsible for the adequacy and accuracy of the disclosure in the filings;
* staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
* the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filings or in response to our comments on your filings.
You may contact Kelly McCusker, Staff Accountant, at (202) 824- or the undersigned at (202) 942-1975 if you have questions.
Sincerely,
Cicely Luckey
Senior Staff Accountant
Show Raw Text
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
March 29, 2005
Mail Stop 04-09
VIA U.S. MAIL AND FAX 1-310-966-9494
Victor J. Coleman
President, Chief Operating Officer and Director
Arden Realty Limited Partnership
11601 Wilshire Boulevard, Fourth Floor
Los Angeles, CA 90025
RE: Arden Realty Limited Partnership
Form 10-K for the year ended December 31, 2004
Dear Mr. Coleman:
We have reviewed the above referenced filings and have the
following
comments. We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents. As such, all persons who are responsible for the
adequacy and accuracy of the disclosure are urged to be certain
that
they have included all information required pursuant to the
Securities Exchange Act of 1934.
Where indicated, we think you should revise your documents in
response to these comments in future filings. If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary. Please be as detailed as necessary
in
your explanation. In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure. After reviewing this information, we may or may not
raise additional comments.
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-K fiscal year ended December 31, 2004
Consolidated Statements of Income, page F-3
1. What is your basis in GAAP for presenting income from
continuing
operations before impairment on investment in securities and how
does
your presentation comply with Rule 5-03 of Regulation S-X and Item
10(e) of Regulation S-K? Prior to the impairment, where did you
record any income / loss related to this investment?
Exhibit 12.1
2. How did you consider the guidance in Item 5-03(d)(1)(c) of
Regulation S-K when including the results of discontinued
operations
within your calculation of ratio of earnings to fixed charges?
* * * *
As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response. Please
furnish a cover letter with your proposed revisions that keys your
responses to our comments and provides any requested supplemental
information. Please file your response letter on EDGAR. Please
understand that we may have additional comments after reviewing
your
responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
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.
In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.
You may contact Kelly McCusker, Staff Accountant, at (202) 824-
5453
or the undersigned at (202) 942-1975 if you have questions.
Sincerely,
Cicely Luckey
Senior Staff Accountant
??
??
??
??
Arden Realty Limited Partnership
March 29, 2005
Page 3
</TEXT>
</DOCUMENT>