UPLOAD: SEC-generated letter
Published on
March 30, 2005
Via Fax & U.S. Mail
Mr. Mathias J. Barton
Chief Financial Officer
R & B, Inc.
3400 East Walnut Street
Colmar, Pennsylvania 18915
RE: R & B, Inc.
Form 10-K for the Fiscal Year Ended December 25, 2004
File No. 1-8974
Dear Mr. Barton:
Based upon an examination restricted solely to considerations
of
the Financial Statements, Management`s Discussion and Analysis,
and
Selected Financial Data, we have the following comments on the
above-
referenced document. Where indicated, we think you should revise
your future filings in response to these comments. 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 response. 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
* * * * *
Please respond to confirm that such comments will be complied
with, or, if certain of the comments are deemed inappropriate,
advise
us of the reason thereof. Please respond within fifteen business
days.
Item 1. Business
Products, page 4
1. Revise future filings to discuss whether your products are
covered
by a standard warranty and discuss the terms of the warranty, if
applicable. Also, revise the notes to your financial statements
to
disclose your accounting policy for warranty costs, if applicable.
In addition, disclose that actual product warranty costs have not
differed materially from accrued estimated amounts or detail the
amounts and reason for significant variations for each period
presented. Further, include a reconciliation of the changes in
your
product warranty liability in the notes to your financial
statements
for each period presented. See paragraph 14 of FIN 45 for
guidance.
Product Development, page 5
2. You state in the first sentence in the first paragraph on page
5
that product development is central to your business. In this
regard, please revise the notes to your financial statements in
future filings to disclose your accounting policy for research and
development costs and include the disclosures required by
paragraph
13 of SFAS 2, if material.
Financial Statements
Note 1. Summary of Significant Accounting Policies
Property and Depreciation
3. As your disclosure provides various ranges of life, it is
unclear
of the specific lives attributable to your various types of
property,
plant and equipment. In this regard, revise future filings to
disclose estimated useful lives as they relate to each type or
class
of property, plant and equipment. See paragraph 5 of APB 12.
Also,
disclose your impairment policy for long-lived assets in
accordance
with SFAS 144.
Note 7. Related Party Transactions
4. We note the disclosure in Note 7 indicating that you amended
certain agreements in November 2001 related to its 1998
acquisition
of Scan-Tech USA/Sweden A.B. in exchange for consideration of
approximately $3.2 million to be paid through December 31, 2005.
In
this regard, supplementally tell us and explain in the notes to
your
financial statements in future filings, the nature of the
amendments
that were made to the agreements and the accounting treatment
being
used for the payments being made as a result of the amendments.
Your
response should also explain why you believe the accounting
treatment
being used with respect to these payments is appropriate.
General
5. Reference is made to the last Risk Factor on page 9. You state
that the Berman Family beneficially owns approximately 42% of your
outstanding Common Stock and is able to elect the Board of
Directors,
determine the outcome of most corporate actions requiring
shareholder
approval, and controls your policies. In this regard, please
revise
the notes to your financial statements in future filings to
disclose
this fact. See the disclosure requirements of SFAS No.57.
Schedule II
6. We note the discussion on page 14 indicating that your reserves
for excess and obsolete inventory were $8.2 million and $8.5
million,
respectively as of December 25, 2004 and December 27, 2003. In
this
regard, please revise future filings to include the activity
impacting your reserves for excess and obsolete inventories on
Schedule II.
Closing
You may contact Katherine Mathis at (202) 942-1994 or, in her
absence, me at (202) 942-1936, if you have any questions regarding
the comments above. Please contact Max Webb, Assistant Director,
at
(202) 942-1850 with any other questions.
Sincerely,
Linda Cvrkel
Branch Chief
Via facsimile: (215) 997-0482
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Mr. Mathias J. Barton
R & B, Inc.
March 30, 2005
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