SEC Comment Letter for APOGEE ENTERPRISES, INC. (APOG) (CIK 0000006845) (APOG) — Mar 26, 2013
APOGEE ENTERPRISES, INC. (APOG) (CIK 0000006845)
Date: March 26, 2013 · CIK: 0000006845 · Accession: 0000000000-13-016046
AI Filing Summary & Sentiment
Referenced dates: January 24, 2013
Letter
March 26 , 2013 Via Facsimile Mr. James S. Porter Chief Financial Officer Apogee Enterprises, Inc. 4400 West 78th Street - Suite 520 Minneapolis, MN 55435
Re: Apogee Enterprises, Inc. Form 10-K for the fiscal year ended March 3, 2012 Filed April 30, 2012 File No. 0 -6365
Dear Mr. Porter :
We have reviewed your response letter to our letter dated January 24, 2013 and have the following additional comment . In our comment, we ask you to provide us with additional information so we may better understand your disclosure s.
Please respond to this letter within ten busine ss days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe ou r comment applies to your facts and circumstances , please tell us why in your response.
After reviewing the information you provide in response to this comment , we may have additional comments.
Form 10 -K for the fiscal year e nded March 3, 2012
Note 16. Business Segments Data, page 54
1. We note your response , and appreciate the additional informatio n you provided, to prior comment seven in our letter dated January 24, 2013. We note you aggregate five operating segments into your Architectural reportable segment , based on your determination that all five operating segment s meet the aggregation criteria in ASC 280 - 10-50-11. Based on the inf ormation you provided , it remains unclear to us that all five operating segmen ts you aggre gate have similar economic characteristics and are similar in all the other areas identified in the accounting literature note d above. In regard to similar economic characteristics, we note significant and sustained differences in the gross margin percentages for several of the operating segments you aggregate. It is also unclear to us that all the operating segments you aggregate are similar in terms of their products, production pro cess, and types of customers serve d. Pleas e provide us a more
Mr. James S. Porter Apogee Enterprises, Inc. March 26 , 2013 Page 2
comprehensive explanation of how you determined that the aggregation of all five operating segments is appro priate . Please also provide us revenues and operating income (loss) for each operating segment for each period presented and for the recently complet ed fiscal year.
You may contact Anne McConnell at (202) 551 -3709 if you have questions regarding this comment .
Sincerely,
/s/ John Cash
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March 26 , 2013
Via Facsimile
Mr. James S. Porter
Chief Financial Officer
Apogee Enterprises, Inc.
4400 West 78th Street - Suite 520
Minneapolis, MN 55435
Re: Apogee Enterprises, Inc.
Form 10-K for the fiscal year ended March 3, 2012
Filed April 30, 2012
File No. 0 -6365
Dear Mr. Porter :
We have reviewed your response letter to our letter dated January 24, 2013 and have the
following additional comment . In our comment, we ask you to provide us with additional
information so we may better understand your disclosure s.
Please respond to this letter within ten busine ss days by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe ou r comment applies to your facts and circumstances , please tell us why in your
response.
After reviewing the information you provide in response to this comment , we may have
additional comments.
Form 10 -K for the fiscal year e nded March 3, 2012
Note 16. Business Segments Data, page 54
1. We note your response , and appreciate the additional informatio n you provided, to prior
comment seven in our letter dated January 24, 2013. We note you aggregate five
operating segments into your Architectural reportable segment , based on your
determination that all five operating segment s meet the aggregation criteria in ASC 280 -
10-50-11. Based on the inf ormation you provided , it remains unclear to us that all five
operating segmen ts you aggre gate have similar economic characteristics and are similar
in all the other areas identified in the accounting literature note d above. In regard to
similar economic characteristics, we note significant and sustained differences in the
gross margin percentages for several of the operating segments you aggregate. It is also
unclear to us that all the operating segments you aggregate are similar in terms of their
products, production pro cess, and types of customers serve d. Pleas e provide us a more
Mr. James S. Porter
Apogee Enterprises, Inc.
March 26 , 2013
Page 2
comprehensive explanation of how you determined that the aggregation of all five
operating segments is appro priate . Please also provide us revenues and operating income
(loss) for each operating segment for each period presented and for the recently
complet ed fiscal year.
You may contact Anne McConnell at (202) 551 -3709 if you have questions regarding
this comment .
Sincerely,
/s/ John Cash
John Cash
Accounting Branch Chief