SEC Comment Letter for Avery Dennison (AVY) — Jun 16, 2011
Avery Dennison Corp
Date: June 16, 2011 · CIK: 0000008818 · Accession: 0000000000-11-037111
AI Filing Summary & Sentiment
Letter
June 16, 2011 Via E-mail
Dean A. Scarborough, Chief Executive Officer Avery Dennison Corporation 150 North Orange Grove Boulevard Pasadena, California 91103 RE: Avery Dennison Corporation Form 10-K for Fiscal Year Ended January 1, 2011 Filed February 28, 2011; DEF 14A for Annual Meeting on April 28, 2011 Filed March 17, 2011 File No. 1-7685 Dear Mr. Scarborough:
We have reviewed your filings 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. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your f acts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have a dditional comments. DEF 14A for Annual Meeting on April 28, 2011
1. We note that you benchmark total direct compensation based upon companies similar in size, global scope and complexity and that you utilize market survey data. To the extent you know the identity of the companie s that comprise the survey data, please confirm that you will disclose the companies in future filings. To the extent you do not know the identity of the companies that comprise the survey data, please confirm that you will add a statement to this effect in future filings. Please provide us with draft disclosure. 2. Please confirm that you will provide the di sclosure required by Item 404(b) of Regulation S-K in future filings. Pleas e provide us with draft disclosure.
Dean A. Scarborough Avery Dennison Corporation June 16, 2011 Page 2
Closing Comments
Please contact Janice McGuirk, examiner at (202) 551-3395 or Pam Howell, legal reviewer at (202) 551-33 57 with any questions.
Sincerely,
/s/ Pamela Howell for John Reynolds
Assistant Director
Show Raw Text
June 16, 2011
Via E-mail
Dean A. Scarborough, Chief Executive Officer Avery Dennison Corporation 150 North Orange Grove Boulevard Pasadena, California 91103 RE: Avery Dennison Corporation
Form 10-K for Fiscal Year Ended January 1, 2011
Filed February 28, 2011; DEF 14A for Annual Meeting on April 28, 2011 Filed March 17, 2011 File No. 1-7685
Dear Mr. Scarborough:
We have reviewed your filings 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.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your f acts and circumstances or do
not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have a dditional comments.
DEF 14A for Annual Meeting on April 28, 2011
1. We note that you benchmark total direct compensation based upon companies similar
in size, global scope and complexity and that you utilize market survey data. To the
extent you know the identity of the companie s that comprise the survey data, please
confirm that you will disclose the companies in future filings. To the extent you do
not know the identity of the companies that comprise the survey data, please confirm
that you will add a statement to this effect in future filings. Please provide us with
draft disclosure.
2. Please confirm that you will provide the di sclosure required by Item 404(b) of
Regulation S-K in future filings. Pleas e provide us with draft disclosure.
Dean A. Scarborough
Avery Dennison Corporation June 16, 2011 Page 2
Closing Comments
Please contact Janice McGuirk, examiner at (202) 551-3395 or Pam Howell, legal
reviewer at (202) 551-33 57 with any questions.
Sincerely,
/s/ Pamela Howell for John Reynolds
Assistant Director