-----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, GWS4GHxaa0ecrqsJ4/frx2LWk3hNZgYo1AFXrsEcCg2HcAdORSUsB73FGpykoAcs uGJ9z/DQBiETi0Xqoe5tHg== 0000000000-06-011722.txt : 20061117 0000000000-06-011722.hdr.sgml : 20061117 20060309152436 ACCESSION NUMBER: 0000000000-06-011722 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060309 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: KINETIC CONCEPTS INC /TX/ CENTRAL INDEX KEY: 0000831967 STANDARD INDUSTRIAL CLASSIFICATION: MISCELLANEOUS FURNITURE & FIXTURES [2590] IRS NUMBER: 741891727 STATE OF INCORPORATION: TX FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 8023 VANTAGE DR CITY: SAN ANTONIO STATE: TX ZIP: 78230 BUSINESS PHONE: 210.524.9000 MAIL ADDRESS: STREET 1: P0 B0X 659508 CITY: SAN ANTONIO STATE: TX ZIP: 78265-9508 PUBLIC REFERENCE ACCESSION NUMBER: 0001047469-05-004404 LETTER 1 filename1.txt Mail Stop 7010 March 9, 2006 Martin J. Landon Vice President and Chief Financial Officer Kinetic Concepts, Inc. 8023 Vantage Drive San Antonio, Texas 78230 Re: Kinetic Concepts, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 Form 10-Q for Fiscal Quarters Ended September 30, 2005 File No. 1-09913 Dear Mr. Landon: We have reviewed your response and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may 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. Prior Comment 2 1. We note the disclosures you intend to provide related to the settlement with Novamedix. Based on the material impact this settlement had on your operating results for the year ended December 31, 2005, it appears to us that you should also disclose and discuss the specific facts and circumstances that occurred during FY 2005 that lead to this settlement. Prior Comment 3 2. We note the disclosures you intend to provide related to the pending litigation with BlueSky, including: * the fact that the court issued rulings on Markman hearings on June 28, 2005 and January 26, 2006 and * the fact that the court dismissed the breach of contract claim against Medela. Please revise your proposed disclosures to address the potential impact, if any, that you believe these events may have on the resolution of the pending litigation. Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Bret Johnson at (202) 551-3753, Anne McConnell at (202) 551-3709 or me at (202) 551-3768 if you have questions regarding our comments. Sincerely, John Hartz Senior Assistant Chief Accountant ?? ?? ?? ?? Martin Landon Kinetic Concepts, Inc. March 9, 2006 Page 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE -----END PRIVACY-ENHANCED MESSAGE-----