SEC Comment Letter for Mueller Water Products, (MWA) — May 12, 2006
Mueller Water Products, Inc.
Date: May 12, 2006 · CIK: 0001350593 · Accession: 0000000000-06-022522
AI Filing Summary & Sentiment
File numbers found in text: 333-131536
Letter
MAIL STOP 7010 May 11, 2006 Gregory E. Hyland Chief Executive Officer Mueller Water Products, Inc. 4211 W. Boy Scout Blvd. Tampa, FL 33607 (813) 871-4811
Re: Mueller Water Products, Inc. Form S-1 File No. 333-131536 Filed May 2, 2006 Form 10-Q/A for the Fiscal Quarter Ended December 31,
Dear Mr. Hyland:
We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General
1. Please disclose all the omitted information in your document. Please note that we may have additional substantive comments once you have completed the missing information.
Dividend Policy, page 8
2. Please revise pages eight and 38 to clarify what you mean by "annual rate" in your statement "annual rate equal to __ % of the price per share in this offering." It is unclear whether you are referring to an annual rate or a fixed amount intended only for the first full fiscal quarter following completion of the offering. If the intent of your disclosure is to state an amount for a regular quarterly dividend, please demonstrate your ability to pay this regular quarterly dividend.
Exhibit 5.1 - Legal Opinion
3. Please revise the opinion to reflect the number of shares, including the over-allotment option, which you will state on your prospectus cover page. 4. Please include the file number for your registration statement.
5. Please delete assumption (1) in the fourth paragraph and file a clean opinion.
Closing Comments
You may contact Dale Welcome, Staff Accountant, at (202) 551- 3865 or in his absence John Cash at (202) 551-3768, who supervised the accounting review, if you have questions regarding comments on the financial statements and related matters. Please contact Craig Slivka, Staff Attorney, at (202) 551-3729 or, in his absence, Lesli Sheppard at (202) 551-3708 with any other questions.
Sincerely,
Pamela Long
Assistant Director
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MAIL STOP 7010
May 11, 2006
Gregory E. Hyland
Chief Executive Officer
Mueller Water Products, Inc.
4211 W. Boy Scout Blvd.
Tampa, FL 33607
(813) 871-4811
Re: Mueller Water Products, Inc.
Form S-1
File No. 333-131536
Filed May 2, 2006
Form 10-Q/A for the Fiscal Quarter Ended December 31,
2005
Dear Mr. Hyland:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. We welcome any questions you may have about
our
comments or any other aspect of our review. Feel free to call us
at
the telephone numbers listed at the end of this letter.
General
1. Please disclose all the omitted information in your document.
Please note that we may have additional substantive comments once
you
have completed the missing information.
Dividend Policy, page 8
2. Please revise pages eight and 38 to clarify what you mean by
"annual rate" in your statement "annual rate equal to __ % of the
price per share in this offering." It is unclear whether you are
referring to an annual rate or a fixed amount intended only for
the
first full fiscal quarter following completion of the offering.
If
the intent of your disclosure is to state an amount for a regular
quarterly dividend, please demonstrate your ability to pay this
regular quarterly dividend.
Exhibit 5.1 - Legal Opinion
3. Please revise the opinion to reflect the number of shares,
including the over-allotment option, which you will state on your
prospectus cover page.
4. Please include the file number for your registration statement.
5. Please delete assumption (1) in the fourth paragraph and file a
clean opinion.
Closing Comments
You may contact Dale Welcome, Staff Accountant, at (202)
551-
3865 or in his absence John Cash at (202) 551-3768, who supervised
the accounting review, if you have questions regarding comments on
the financial statements and related matters. Please contact
Craig
Slivka, Staff Attorney, at (202) 551-3729 or, in his absence,
Lesli
Sheppard at (202) 551-3708 with any other questions.
Sincerely,
Pamela Long
Assistant Director
cc: Vincent Pagano, Jr., Esq.
Igor Fert, Esq.
(212) 455-2502
Gregory E. Hyland
Mueller Water Products, Inc.
Page 1 of 2
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
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