SEC Comment Letter for TECHPRECISION CORP (TPCS) (CIK 0001328792) (TPCS) — Oct 24, 2007
TECHPRECISION CORP (TPCS) (CIK 0001328792)
Date: Oct. 24, 2007 · CIK: 0001328792 · Accession: 0000000000-07-052153
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Letter
OCT ~13~2006 17: 08 S I CHENZ I A ROSS FR I EDMAN 212 930 9725 P.01/01 SICHENZIA R.OSS FRIEDMAN FERENCE LLP i' l ' " i"'\~ r;~. t' ,1 ',,"". '.) ;'\;'i ..in,. , October 13, 2006 aI8vitskv~si1.com 212-981.6767(0ID) 1 BY TELECOPIER - (202) 772-9206 SusamReily, Esq. Secunties and Exchange Commssion 100 F StreetNE, Mail Stop 3561 Washington, DC 20549 Re: Techprecision Corporation Form SB-2, Filed August 28, 2006 File No. 333w133509 Dear Ms. Reilly: As we discussed during our earlier conversation this morning, with respect to comment 40 of your letter to Techprecision dated October 11, 2006, Techprecision is a contract manufacturer (through its operating subsidiary, Ranor, Inc. http://ww.ranor.com) of large metal fabrications up to 100 tons in size. The Company provides both large fabricating and machining operations to bring its customers' projects to fruition. In most cases, these services are provided for one-of-a~kind projects, and therefore no on-going production work is accorded to the operation. In some cases, however, the Company does produces a number of the same units, however, the units have never been produced under long-term contracts. Each project that Company completes is pursuant to an individual purchase order. The Company performs work in many sectors, including aerospace, nuclear, shipbuilding, militay/defense, industral machinery and alternative energy. Due to existing confidentiality agreements with customers which (in may cases work performed at the facility is subject to national security requirements), results in the fact that the Company is, through written agreements, unable to divulge the names of the organizations for which it provides contract manufacturing services. One customer in paricular, which accounted for more than 10% of the Company's revenue in the three months ended June 30, 2006, has officially told the Company that its name in no way is to be made par of any public anouncements or it would result in the manufacturing work being pulled from the Company and placed with another facilty. The Company can indicate revenue amounts and industr sectors in which it performs its services, yet it is contractually prohibited from divulging the actual names and products of these customers. We trust this explanation adequately explains our current situation, along with meeting the disclosure requirements of the SEC. Please contaCt me at (212) 981-6767 if you have any questions.ver~lÍt g(~evitsky P.C. 11~Jl!," ..,ve;'Nl.lõ '''if "I'j'-li! ÀMt!iilC£,$ J N'EW YORK. i-EW ..ORK j DC! L i: 'l ~ 1",' ',J3U ',i7i:O i F'¿ 'i:. 9::ti ','72:, i W'NV~'.~R.'F.C:QM TOTAL P.01
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OCT ~13~2006 17: 08 S I CHENZ I A ROSS FR I EDMAN 212 930 9725 P.01/01 SICHENZIA R.OSS FRIEDMAN FERENCE LLP i' l ' " i"'\~ r;~. t' ,1 ',,"". '.) ;'\;'i ..in,. , October 13, 2006 aI8vitskv~si1.com 212-981.6767(0ID) 1 BY TELECOPIER - (202) 772-9206 SusamReily, Esq. Secunties and Exchange Commssion 100 F StreetNE, Mail Stop 3561 Washington, DC 20549 Re: Techprecision Corporation Form SB-2, Filed August 28, 2006 File No. 333w133509 Dear Ms. Reilly: As we discussed during our earlier conversation this morning, with respect to comment 40 of your letter to Techprecision dated October 11, 2006, Techprecision is a contract manufacturer (through its operating subsidiary, Ranor, Inc. http://ww.ranor.com) of large metal fabrications up to 100 tons in size. The Company provides both large fabricating and machining operations to bring its customers' projects to fruition. In most cases, these services are provided for one-of-a~kind projects, and therefore no on-going production work is accorded to the operation. In some cases, however, the Company does produces a number of the same units, however, the units have never been produced under long-term contracts. Each project that Company completes is pursuant to an individual purchase order. The Company performs work in many sectors, including aerospace, nuclear, shipbuilding, militay/defense, industral machinery and alternative energy. Due to existing confidentiality agreements with customers which (in may cases work performed at the facility is subject to national security requirements), results in the fact that the Company is, through written agreements, unable to divulge the names of the organizations for which it provides contract manufacturing services. One customer in paricular, which accounted for more than 10% of the Company's revenue in the three months ended June 30, 2006, has officially told the Company that its name in no way is to be made par of any public anouncements or it would result in the manufacturing work being pulled from the Company and placed with another facilty. The Company can indicate revenue amounts and industr sectors in which it performs its services, yet it is contractually prohibited from divulging the actual names and products of these customers. We trust this explanation adequately explains our current situation, along with meeting the disclosure requirements of the SEC. Please contaCt me at (212) 981-6767 if you have any questions.ver~lÍt g(~evitsky P.C. 11~Jl!," ..,ve;'Nl.lõ '''if "I'j'-li! ÀMt!iilC£,$ J N'EW YORK. i-EW ..ORK j DC! L i: 'l ~ 1",' ',J3U ',i7i:O i F'¿ 'i:. 9::ti ','72:, i W'NV~'.~R.'F.C:QM TOTAL P.01