SEC Comment Letter for TECHPRECISION CORP (TPCS) (CIK 0001328792) (TPCS) — Mar 10, 2010
TECHPRECISION CORP (TPCS) (CIK 0001328792)
Date: March 10, 2010 · CIK: 0001328792 · Accession: 0000000000-10-013375
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 26, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631
DIVISION OF CORPORATION FINANCE
Mail Stop 4631 March 10, 2010
via U.S. mail and facsimile
Louis A. Winoski, Chief Executive Officer Techprecision Corporation 1 Bella Drive Westminster, MA 01473 RE: Techprecision Corporation Form 10-K for the Fiscal Year Ended March 31, 2009 Filed June 25, 2009 Form 10-Q for the Fiscal Qu arter Ended September 30, 2009 File No. 51378 Dear Mr. Winoski:
We have reviewed your response letter dated February 26, 2010 and have the following additional comment. If you disagree, we will consider your explanation as to why our comment is inapplicable. Form 10-K for the Fiscal Year Ended March 31, 2009
Item 7. Management’s Discussion and Analys is of Financial Condition and Results of Operations, page 7 General
1. In your response to prior comment 1, you state you will provide expanded disclosure in future filings, including a quantified analysis of the impact from material customer cancellations of purc hase orders and other known material trends and uncertainties affecting future sales to your significant customers. However, the MD&A in your Form 10-Q for the period ending December 31, 2009, does not include an analysis of the expected impact from the cancelled orders and reduced sales to GT Solar, your largest customer. Please refer to our prior comment and provide us with an example of disclosure you intend to include in your next quarterly report.
* * * *
Mr. Winoski Techprecision Corporation March 10, 2010 Page 2 As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please understand that we may have additiona l comments after reviewing your response to our comment. You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her absence the undersigned Accounting Branch Chief at (202) 551-3355 if you have questions regarding comments on the financ ial statements and related matters.
Sincerely,
T e r e n c e O ’ B r i e n A c c o u n t i n g B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
Mail Stop 4631
March 10, 2010
via U.S. mail and facsimile
Louis A. Winoski, Chief Executive Officer Techprecision Corporation 1 Bella Drive Westminster, MA 01473
RE: Techprecision Corporation
Form 10-K for the Fiscal Year Ended March 31, 2009
Filed June 25, 2009 Form 10-Q for the Fiscal Qu arter Ended September 30, 2009
File No. 51378
Dear Mr. Winoski:
We have reviewed your response letter dated February 26, 2010 and have the
following additional comment. If you disagree, we will consider your explanation as to
why our comment is inapplicable. Form 10-K for the Fiscal Year Ended March 31, 2009
Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 7
General
1. In your response to prior comment 1, you state you will provide expanded
disclosure in future filings, including a quantified analysis of the impact from material customer cancellations of purc hase orders and other known material
trends and uncertainties affecting future sales to your significant customers.
However, the MD&A in your Form 10-Q for the period ending December 31, 2009, does not include an analysis of the expected impact from the cancelled orders and reduced sales to GT Solar, your largest customer. Please refer to our
prior comment and provide us with an example of disclosure you intend to
include in your next quarterly report.
* * * *
Mr. Winoski
Techprecision Corporation March 10, 2010 Page 2
As appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response. Please file your response letter on EDGAR.
Please understand that we may have additiona l comments after reviewing your response
to our comment. You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her
absence the undersigned Accounting Branch Chief at (202) 551-3355 if you have
questions regarding comments on the financ ial statements and related matters.
Sincerely,
T e r e n c e O ’ B r i e n A c c o u n t i n g B r a n c h C h i e f