-----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, WkmJ3SuTjoqk8taDmajvu2w50wwhX8cYdFWOlwSwRxeU5VZ84OWk1p4vdaRZNE2O oZ+m2+/XR4uhFlG1D/OswQ== 0000000000-05-041788.txt : 20060926 0000000000-05-041788.hdr.sgml : 20060926 20050812134559 ACCESSION NUMBER: 0000000000-05-041788 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050812 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: PROTECTION ONE INC CENTRAL INDEX KEY: 0000916230 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-MISCELLANEOUS BUSINESS SERVICES [7380] IRS NUMBER: 931063818 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 1035 N. 3RD ST. STREET 2: SUITE 101 CITY: LAWRENCE STATE: KS ZIP: 66044 BUSINESS PHONE: 785 856 5500 MAIL ADDRESS: STREET 1: 1035 N. 3RD ST. STREET 2: SUITE 101 CITY: LAWRENCE STATE: KS ZIP: 66044 PUBLIC REFERENCE ACCESSION NUMBER: 0001104659-05-012643 LETTER 1 filename1.txt Mail Stop 3561 August 10, 2005 Via U.S. Mail and Fax (785) 856-9910 Mr. Darius G. Nevin Executive Vice President and Chief Financial Officer Protection One, Inc. 1035 N. 3rd Street Suite 101 Lawrence, Kansas 66044 RE: Protection One, Inc. Protection One Alarm Monitoring Inc. Form 10-K for the fiscal year ended December 31, 2004 Form 10-K/A for the fiscal year ended December 31, 2004 Filed March 17, 2005 and March 24, 2005, respectively Form 10-Q for the quarter ended March 31, 2005 Filed May 16, 2005 File Nos. 1-12181-01 and 1-12181, respectively Dear Mr. Nevin: We have reviewed your supplemental response letter dated May 27, 2005 well as your filings and have the following comments. As noted in our comment letter dated April 29, 2005, 2005, we have limited our review to your financial statements and related disclosures and do not intend to expand our review to other portions of your documents. Form 10-K/A for the year ended December 31, 2004 Notes to Consolidated Financial Statements 2, Summary of Significant Accounting Policies (b) Revenue Recognition, page 9 1. We note your response to our prior comment 9 and your statement that in an arrangement where the Company retains title to the system, you believe that there is "only one unit of accounting since there is not a sale of the system." Tell us your consideration of EITF 01-8 regarding whether your arrangements contain a lease of the security system. 2. Your response to prior comment 9 did not specifically address your deferral of revenues and direct costs relative to when you price the system lower than you otherwise would because of an accompanying service agreement. Provide us with more details of what you mean by this statement and cite your basis in the accounting literature. Form 10-Q for the quarterly period ended March 31, 2005 Notes to Condensed Consolidated Financial Statements 1. Basis of Consolidation and Interim Financial Information, page 7 3. We note the reduction of deferred customer acquisition costs and revenues "which have been subsumed into the estimated fair market value adjustment for customer accounts." Tell us what the referenced statement means and why you believe this accounting treatment is appropriate. Also, tell us the underlying assumptions used to estimate fair value of the deferred customer acquisition costs. * * * * Please file your response to these comments within 10 business days via EDGAR or tell us when you will provide us with a response. You may contact Kathryn Jacobson, Staff Accountant, at (202) 551-3365 or Kyle Moffatt, Branch Chief Accountant, at (202) 551-3836 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3810 with any other questions. Sincerely, Larry Spirgel Assistant Director ?? ?? ?? ?? Mr. Darius G. Nevin Protection One Inc. Protection One Alarm Monitoring Inc. August 10, 2005 Page 2 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE -----END PRIVACY-ENHANCED MESSAGE-----