SEC Comment Letter for Avery Dennison (AVY) — Jul 15, 2014
Avery Dennison Corp
Date: July 15, 2014 · CIK: 0000008818 · Accession: 0000000000-14-035546
AI Filing Summary & Sentiment
Referenced dates: May 7, 2014
Letter
July 15 , 2014 Via E -mail Mitchell R. Butier Senior Vice President and Chief Financial Officer Avery Dennison Corporation 207 Goode Avenue Glendale , California 91203
Re: Avery Dennison Corporation Form 10-K for Fiscal Year Ended December 28, 2013 Filed February 26 , 2014 Supplemental response dated June 4, 2014 File No. 001 -07685
Dear Mr. Butier :
We have reviewed your response letter 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 advising us when you wil l provide the requested response. If you do not believe our comments apply to your facts 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 additional comments.
Form 10 -K for Fiscal Year Ended December 28, 2013
Notes to Consolidated Financial Statements
Note 13 – Segment Information, p age 58
1. We note your response to comment 4 in our letter dated May 7, 2014. Please provide us with the following information with regard to your operating structure:
Tell us about the factors you considered in identifying your Chief Executive Officer as your chief operating decision maker (“CODM”);
Mr. Mitchell Butier Avery Dennison Corporation July 15, 2014 Page 2
Provide a copy of your organization chart which identifies the positions, roles , or functions that report directly to your CODM;
Explain in greater detail the responsibilities of the segment managers identified in your prior response and tell us about the manner in which they typically interact with your CODM; and
Describe the process through which your CODM reviews performance and makes decisions about the allocation of resou rces and provide us with a copy of the reports or information used in connection with these functions for the fiscal year ended December 28, 2013 .
You may contact Svitlana Sweat, Staff Accountant at 202 -551-3326 or me at 202 -551- 3311 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Ethan Horowitz
Show Raw Text
July 15 , 2014 Via E -mail Mitchell R. Butier Senior Vice President and Chief Financial Officer Avery Dennison Corporation 207 Goode Avenue Glendale , California 91203 Re: Avery Dennison Corporation Form 10-K for Fiscal Year Ended December 28, 2013 Filed February 26 , 2014 Supplemental response dated June 4, 2014 File No. 001 -07685 Dear Mr. Butier : We have reviewed your response letter 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 advising us when you wil l provide the requested response. If you do not believe our comments apply to your facts 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 additional comments. Form 10 -K for Fiscal Year Ended December 28, 2013 Notes to Consolidated Financial Statements Note 13 – Segment Information, p age 58 1. We note your response to comment 4 in our letter dated May 7, 2014. Please provide us with the following information with regard to your operating structure: Tell us about the factors you considered in identifying your Chief Executive Officer as your chief operating decision maker (“CODM”); Mr. Mitchell Butier Avery Dennison Corporation July 15, 2014 Page 2 Provide a copy of your organization chart which identifies the positions, roles , or functions that report directly to your CODM; Explain in greater detail the responsibilities of the segment managers identified in your prior response and tell us about the manner in which they typically interact with your CODM; and Describe the process through which your CODM reviews performance and makes decisions about the allocation of resou rces and provide us with a copy of the reports or information used in connection with these functions for the fiscal year ended December 28, 2013 . You may contact Svitlana Sweat, Staff Accountant at 202 -551-3326 or me at 202 -551- 3311 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Ethan Horowitz Ethan Horowitz Branch Chief