SEC Comment Letter for APOGEE ENTERPRISES, INC. (APOG) (CIK 0000006845) (APOG) — Apr 30, 2013
APOGEE ENTERPRISES, INC. (APOG) (CIK 0000006845)
Date: April 30, 2013 · CIK: 0000006845 · Accession: 0000000000-13-023501
AI Filing Summary & Sentiment
Letter
April 30 , 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 April 9 , 2013 and the additional information you provided in our conference call on April 29, 2013 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 t his 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 ended March 3, 2012
Note 16. Business Segments Data, page 54
1. We note your response to prior comment one in our lett er dated March 26, 2013 as well as the additional information you provided in our conference call on April 29, 2013. We note you aggregate five operating segments into your Architectural reportable segment based on your determination that all five operati ng segment s meet the aggregation criteria in ASC 280 -10-50-11. Based on the inf ormation you provided , it does not appear to us that all five operating segmen ts you aggregate have simil ar economic characteristics, due to significant and sustained differences in their gross margin percentages, or are similar in all the other areas identified in the accounting literature note d above. Pleas e reconsider the appropriateness of your aggregation of five operating segments in to your
Mr. James S. Porter Apogee Enterprises, Inc. April 30 , 2013 Page 2
Architectural reportable segment and provide us an updated analysis.
You may contact Anne McConnell at (202) 551 -3709 if you have questions regarding this comment .
Sincerely,
/s/ John Cash
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April 30 , 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 April 9 , 2013 and the additional
information you provided in our conference call on April 29, 2013 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 t his 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 ended March 3, 2012
Note 16. Business Segments Data, page 54
1. We note your response to prior comment one in our lett er dated March 26, 2013 as well
as the additional information you provided in our conference call on April 29, 2013. We
note you aggregate five operating segments into your Architectural reportable segment
based on your determination that all five operati ng segment s meet the aggregation criteria
in ASC 280 -10-50-11. Based on the inf ormation you provided , it does not appear to us
that all five operating segmen ts you aggregate have simil ar economic characteristics, due
to significant and sustained differences in their gross margin percentages, or are similar in
all the other areas identified in the accounting literature note d above. Pleas e reconsider
the appropriateness of your aggregation of five operating segments in to your
Mr. James S. Porter
Apogee Enterprises, Inc.
April 30 , 2013
Page 2
Architectural reportable segment and provide us an updated analysis.
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