LETTER
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Mail Stop 3561
May 9, 2006
Via U.S. Mail
Mr. Jeffrey I. Badgley
President and Co-Chief Executive Officer
Miller Industries, Inc.
8503 Hilltop Drive
Ooltewah, Tennessee 37363
RE: Miller Industries, Inc.
Form 10-K for the year ended December 31, 2005
Filed March 14, 2006
File No. 001-14124
Dear Mr. Badgley
We have reviewed your filings and have the following comment.
Where
indicated, we think you should revise your document 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.
In our comment, 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 filings. We look
forward to working with you in these respects. We welcome any
questions you may have about our comments or on any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Annual Report on Form 10-K for the year ended December 31, 2005
Financial Statements, page F-1
Consolidated Statements of Operations, page F-4
1. We refer to your response to our prior comment 2. Rule 4-08(k)
of
Regulation S-X requires that related party transactions be
identified
on the face of financial statements rather than in the footnotes
regardless of materiality. Furthermore, we note that the 2005
revenue received from Datapath was almost 7% of total revenues.
Please revise future filings to include separate line items for
all
balance sheet, income statement and cash flow items related to
Datapath.
As appropriate, please respond to this comment within 10 business
days or tell us when you will provide us with a response. Please
furnish a cover letter that keys your responses to our comment and
provides any requested information. Detailed cover letters
greatly
facilitate our review. Please understand that we may have
additional
comments after reviewing your responses to our comment.
You may contact Heather Tress at (202) 551-3624 or Lyn Shenk at
(202)
551-3380 if you have questions.
Sincerely,
Linda Cvrkel
Branch Chief
Mr. Jeffrey I. Badgley
Miller Industries, Inc.
May 9, 2006
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