-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, HuDiHgwRKLB/mx9B91IZo4oSPh2Hro+EJJUG1PwT0g2Eo6qrpntBJjwS4DOZbtT5 HIUoAMQKYtYSLfUqd3yj3w== 0000897101-06-000743.txt : 20061025 0000897101-06-000743.hdr.sgml : 20061025 20060407152248 ACCESSION NUMBER: 0000897101-06-000743 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060407 FILER: COMPANY DATA: COMPANY CONFORMED NAME: MTS SYSTEMS CORP CENTRAL INDEX KEY: 0000068709 STANDARD INDUSTRIAL CLASSIFICATION: MEASURING & CONTROLLING DEVICES, NEC [3829] IRS NUMBER: 410908057 STATE OF INCORPORATION: MN FISCAL YEAR END: 1001 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 14000 TECHNOLOGY DR CITY: EDEN PRAIRIE STATE: MN ZIP: 55344-2290 BUSINESS PHONE: 6129374000 MAIL ADDRESS: STREET 1: 14000 TECHNOLOGY DR CITY: EDEN PRAIRIE STATE: MN ZIP: 55344 FORMER COMPANY: FORMER CONFORMED NAME: RESEARCH INC DATE OF NAME CHANGE: 19670216 CORRESP 1 filename1.htm MTS Systems Corporation SEC Correspondence dated April 6, 2006

 

April 6, 2006




Ms. Angela J. Crane

Accounting Branch Chief

Securities and Exchange Commission

Division of Corporate Finance

701 First St. NE

Washington, D.C. 20549

 

 

Re:

Comment Letter Dated March 23, 2006

 

 

 

MTS Systems Corporation

 

 

 

Form 10-K for the fiscal year ended October 1, 2005

 

 

File No. 0-02382

 

 

Dear Ms. Crane:

 

As requested, we are providing the following information in connection with your letter dated March 23, 2006:

 

Form 10-K for the period ending October 1, 2005

 

Cash Flow Statement, page F-7

 

 

1.

Please refer to prior comment 2. We note in future filings you will report cash flows from discontinued operations separately on the face of the cash flow statement. While we do not believe your previous presentation complied with SFAS 95, we will not object if you retroactively modify your presentation similar to a change in accounting method (without referring to the correction of an error) provided that you comply with the following:

 

 

–

If you expect to request effectiveness of a registration statement or mail a transactional proxy statement prior to filing your next periodic report, you include the changed presentation as well as the annual cash flow information requested below in that registration/proxy statement prior to effectiveness.

 

 

–

You label either the column heading or the marginal heading as “revised” or “restated.” Characterizing the modification as “reclassified” will not suffice.

 

 

–

You make specific and prominent footnote disclosure to the effect that the company has separately disclosed the operating, investing and financing portions of the cash flows attributable to discontinued operations, which in prior periods were reported on a combined basis as a single amount.

 

 


 

 

 

–

Since your next periodic report is a Form 10-Q, you quantify and present separate totals of operating, investing and financing cash flows from discontinued operations for the most recently completed three fiscal years.

 

The Company will comply with the above presentation and disclosure requirements related to discontinued operations cash flows in its Form 10-Q for the fiscal quarter ended April 1, 2006 and in subsequent periodic reports, as appropriate.

 

If you have any questions, please contact Lynn Blake, Corporate Controller, at (952) 937-4020, or myself at (952) 937-4005.

 

Sincerely,


/s/ Susan E. Knight 

 

Susan E. Knight

Vice President and Chief Financial Officer

 

 






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