SEC Filing Html Data
December
4, 2009
U.S.
Securities and Exchange Commission
100 F
Street, N.E.
Mail Stop
4631
Washington,
D.C. 20549
Attention: Mr.
Terence O’Brien, Accounting Branch Chief
Division of Corporation
Finance
CC: Ms.
Tracey Houser, Staff Accountant
Division of Corporation Finance
Mr.
Edward M. Kelly, Senior Counsel
Division of Corporation
Finance
Ms. Pamela A. Long, Associate
Director
Division of Corporation
Finance
RE: CompX
International Inc.
Form 10-K for the Fiscal Year Ended
December 31, 2008, Filed February 26, 2009
Forms 10-Q for the Fiscal Quarters
Ended March 31, 2009, June 30, 2009 and
September 30, 2009
File No. 1-13905
Dear Mr.
O’Brien
Reference
is made to the Staff’s letter dated November 25, 2009, (the “Comment Letter”),
which sets forth comments of the Staff regarding the above referenced Form 10-K
and Forms 10-Q of CompX International Inc. (“CompX). CompX has responded to the
Comment Letter as follows. The responses are numbered to correspond
to the numbers of the Comment Letter.
Form 10-K for the Fiscal
Year Ended December 31, 2008
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Exhibits 10.1 and
10.10
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1.
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We
reviewed the response to the prior comment 12 and are unable to
concur. As noted previously, there is no provision in Item
601(b)(10) of Regulation S-K for excluding schedules or similar
attachments. While we note that your exhibit list states that
you will furnish schedules and attachments upon request for each of these
exhibits, please be aware that this provision only applies to exhibits
filed under Item 601(b)(2) of Regulation S-K (plans of acquisition,
reorganizations, etc.), and not to material contracts filed under Item
601(b)(10). Further, Rule 12b-31, which you cite in your
response, relates to the omission of substantially identical documents and
requires the filing of a schedule identifying the other documents omitted
and setting forth the material details in which the documents differ from
the document of which a copy is filed. It does not pertain to
the exclusion of schedules and attachments to documents filed as
exhibits. Please refile the captioned exhibits, with all
schedules and exhibits attached, in your next Exchange Act
filing.
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In our
Annual Report on Form 10-K for the year ending December 31, 2009, we will refile
the captioned exhibits indicated above and include all schedules, exhibits,
annexes or similar attachments to the documents as part of such
filing.
If you
have any questions regarding our responses to the Comment Letter, please feel
free to call me at (972) 448-1413. I can also be reached via
facsimile at (972) 448-1408 or via email at dhalbert@compx.com.
Sincerely,
CompX
International Inc.
By: _/s/ Darryl R.
Halbert
Darryl R. Halbert,
Vice President, Chief Financial
Officer
and
Controller
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