SEC Comment Letter for Avery Dennison (AVY) — Oct 7, 2014
Avery Dennison Corp
Date: Oct. 7, 2014 · CIK: 0000008818 · Accession: 0000000000-14-050300
AI Filing Summary & Sentiment
Referenced dates: July 15, 2014
Letter
October 7, 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 August 15, 2014 File No. 001 -07685
Dear Mr. Butier :
We have reviewed your response letter and have the following comments. Where indicated, we think you should revise your documents in response to these comments. 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. After reviewing this informa tion, we may raise additional comments .
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comm ents apply to your facts and circumstances or do not believe an amendment is appropriate, pleas e tell us why in your response.
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 1 in our comment letter dated July 15, 2014. It appears that the reports provided with your response include information regarding revenues from external customers by product. Please tell us how you considered the guidance per FASB ASC 280 -10-50-40 and concluded that it is impracticable to provide this type of disclosure .
Mr. Mitchell Butier Avery Dennison Corporation October 7, 2014 Page 2
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 finan cial statements and related matters.
Sincerely,
/s/ Ethan Horowitz
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October 7, 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 August 15, 2014 File No. 001 -07685 Dear Mr. Butier : We have reviewed your response letter and have the following comments. Where indicated, we think you should revise your documents in response to these comments. 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. After reviewing this informa tion, we may raise additional comments . Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comm ents apply to your facts and circumstances or do not believe an amendment is appropriate, pleas e tell us why in your response. 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 1 in our comment letter dated July 15, 2014. It appears that the reports provided with your response include information regarding revenues from external customers by product. Please tell us how you considered the guidance per FASB ASC 280 -10-50-40 and concluded that it is impracticable to provide this type of disclosure . Mr. Mitchell Butier Avery Dennison Corporation October 7, 2014 Page 2 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 finan cial statements and related matters. Sincerely, /s/ Ethan Horowitz Ethan Horowitz Branch Chief