SEC Comment Letter for Navios Maritime Partners L.P. (NMM) (CIK 0001415921) (NMM) — Jan 3, 2012
Navios Maritime Partners L.P. (NMM) (CIK 0001415921)
Date: Jan. 3, 2012 · CIK: 0001415921 · Accession: 0000000000-12-000196
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33811
Referenced dates: December 22, 2011
Letter
January 3, 2012 Via E-Mail Mr. Efstratios Desypris Chief Financial Officer Navios Maritime Partners L.P. 85 Akti Miaouli Street Piraeus, Greece 185 38 Re: Navios Maritime Partners L.P. Form 20-F for the year ended December 31, 2010 Filed March 1, 2011 Response Letter dated December 22, 2011 File No. 001-33811
Dear Mr. Desypris: We have reviewed your response letter da ted December 22, 2011 and have the following comment. Please respond to this letter within 10 bus iness days by confirming that you will revise your document in future filings (unless otherw ise indicated) and pr oviding any requested information. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 20-F for the Year Ended December 31, 2010
Item 5. Operating and Financial Review and Prospects
Critical Accounting Policies
Impairment of Long-lived Assets, page 71
1. We note from your response to our prior co mment two that you will revise the Critical Accounting Policies section in MD&A in future filings to disclose the aggregate number of vessels that you own and operate and the aggregate carrying valu e of those vessels, including any associated value of the related time charters. We continue to believe that it would be beneficial to invest ors to include a table summari zing your owned vessels that details by vessel, the date of acquisition, purch ase price and carrying value at the balance
Mr. Efstratios Desypris Navios Maritime Partners L.P. January 3, 2012 Page 2
sheet date. Also, please identify within this table those vessels whose estimated market values are less than their carrying values. Please consider revi sing future filings accordingly.
You may contact Claire Erla nger at (202) 551-3301 if you have questions regarding comments on the financial statements and relate d matters. Please contact me at (202) 551-3813 with any other questions. Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief
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January 3, 2012 Via E-Mail Mr. Efstratios Desypris Chief Financial Officer Navios Maritime Partners L.P. 85 Akti Miaouli Street Piraeus, Greece 185 38 Re: Navios Maritime Partners L.P. Form 20-F for the year ended December 31, 2010 Filed March 1, 2011 Response Letter dated December 22, 2011 File No. 001-33811 Dear Mr. Desypris: We have reviewed your response letter da ted December 22, 2011 and have the following comment. Please respond to this letter within 10 bus iness days by confirming that you will revise your document in future filings (unless otherw ise indicated) and pr oviding any requested information. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 20-F for the Year Ended December 31, 2010 Item 5. Operating and Financial Review and Prospects Critical Accounting Policies Impairment of Long-lived Assets, page 71 1. We note from your response to our prior co mment two that you will revise the Critical Accounting Policies section in MD&A in future filings to disclose the aggregate number of vessels that you own and operate and the aggregate carrying valu e of those vessels, including any associated value of the related time charters. We continue to believe that it would be beneficial to invest ors to include a table summari zing your owned vessels that details by vessel, the date of acquisition, purch ase price and carrying value at the balance Mr. Efstratios Desypris Navios Maritime Partners L.P. January 3, 2012 Page 2 sheet date. Also, please identify within this table those vessels whose estimated market values are less than their carrying values. Please consider revi sing future filings accordingly. You may contact Claire Erla nger at (202) 551-3301 if you have questions regarding comments on the financial statements and relate d matters. Please contact me at (202) 551-3813 with any other questions. Sincerely, /s/ Linda Cvrkel Linda Cvrkel Branch Chief