SEC – ‘UPLOAD’ from 5/4/05 re: Avondale Inc – ‘LETTER’

On:  Wednesday, 5/4/05, at 9:20am ET   ·   Private-to-Public:  Filing ¶  –  Release Delayed to:  9/25/06   ·   Accession #:  0-5-21644

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Delayed-Release Comment or Other Letter from the SEC
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: LETTER      Comment or Other Letter from the SEC                   2±    10K 


Mail Stop 3-8                                                                   

                                                                     May 4, 2005

By Facsimile and U.S. Mail                                                      

Mr. G. Stephen Felker                                                           
Chairman, President and Chief Executive Officer                                 
Avondale Incorporated                                                           
506 South Broad St                                                              
Monroe, GA 30655                                                                

RE:     Form 10-K for the fiscal year ended August 27, 2004     
Forms 10-Q for the quarters ended November 26, 2004 and February                
25,                                                                             
2005                                                                            

Dear Mr. Felker:                                                                

We have reviewed the responses in your letter dated April 26,   
2005 and have the following additional comment.  Where indicated,               
we                                                                              
think you should revise your disclosures in future filings in                   
response to this comment.  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                        
explanation                                                                     
so we may better understand your disclosure.  After reviewing this              
information, we may or may not raise additional comments.                       

We welcome any questions you may have about our comment or on   
any other aspect of our review.  Feel free to call us at the                    
telephone numbers listed at the end of this letter.                             

**********************************                                              

FORM 10-K FOR THE FISCAL YEAR ENDED AUGUST 27, 2004                             

Item 6. Selected Financial Data, page 14                                        

1. Based on your response to prior comment 4, it is our                         
understanding                                                                   
that the ratio of "Adjusted EBITDA to interest expense, net and                 
discount and expenses on sale of receivables" is not one of your                
debt                                                                            
covenants.  Accordingly and as previously requested, please tell                
us                                                                              
in detail why you nonetheless believe you are permitted to include              
this measure in your filings in light of the prohibitions in Item               
10(e) of Regulation S-K.  Also, if you continue to believe that                 
inclusion of this ratio is appropriate, please supplementally show              
us                                                                              
what your revised disclosures in future filings will look like                  
with                                                                            
respect to this measure.                                                        

**********************************                                              

As appropriate, please respond to this comment within 10        
business days or tell us when you will provide us with a response.              
Detailed supplemental response letters greatly facilitate our                   
review.                                                                         
Please file your supplemental response letter on EDGAR.  Please                 
understand that we may have additional comments after reviewing                 
your                                                                            
response to our comment.                                                        

If you have any questions regarding this comment, please        
direct                                                                          
them to Staff Accountant Andrew Blume at (202) 551-3254.  In his                
absence, direct your questions to Robyn Manuel at (202) 551-3823.               
Any other questions regarding disclosure issues may be directed to              
me                                                                              
at (202) 551-3843.                                                              

                                          Sincerely,

                                                     George F. Ohsiek, Jr.
                                            Branch Chief

Mr. G. Stephen Felker                                                           
Chairman, President and Chief Executive Officer                                 
Avondale Incorporated                                                           
May 4, 2005                                                                     
Page 1                                                                          

Dates Referenced Herein   and   Documents Incorporated by Reference

This ‘UPLOAD’ Filing		Date		Other Filings
Release Delayed to:		9/25/06		CORRESP,  UPLOAD
Filed on:		5/4/05		UPLOAD
		4/26/05		CORRESP,  UPLOAD
		2/25/05		10-Q,  UPLOAD
		11/26/04		10-Q,  UPLOAD
		8/27/04		10-K,  UPLOAD
				List all Filings

1 Previous Filing that this Filing References

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

11/12/04  Avondale Inc.                     10-K        8/27/04    8:734K                                   Bowne of Atlanta Inc./FA