SEC Comment Letter for CONAGRA BRANDS INC. (CAG) (CIK 0000023217) (CAG) — Dec 29, 2015
CONAGRA BRANDS INC. (CAG) (CIK 0000023217)
Date: Dec. 29, 2015 · CIK: 0000023217 · Accession: 0000000000-15-059671
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4628 December 29, 2015 Via E -mail John F. Gehring Chief Financial Officer Conagra Foods, Inc. One Conagra Drive Omaha, NE 68102
Re: Conagra Foods, Inc. Form 10-K for Fiscal Year Ended May 31, 2015 Response Dated December 3, 2015 File No. 001 -07275
Dear Mr. Gehring :
We have reviewed your December 3, 2015 response to our comment 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments a pply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our November 20, 2015 letter .
Form 10 -K for Fiscal Year Ended May 31, 2015
Notes to Consolidated Financial Statements
Note 7 – Investments in Joint Ventures, page 58
1. Your response to prior comment 2 states that the disposal of a controlling interest in your flour mil ling operations constituted a strategic shift that had a major impact on your operations and financial results as your milling operations were the last of your purely commodity -based operations. It does not appear that your response adequately explains the qualitative evidence support ing the presentation of discontinued operations pursuant to ASU 2014 -08. Please p rovide us with additional information regarding the qualitative factors considered by management in determining that this presentation was app ropriate .
John F. Gehring Conagra Foods, Inc. December 29, 2015 Page 2
You may contact Sandy Eisen at (202) 551 -3864 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3311 with any other questions.
Sincerely,
/s/ Ethan Horowitz
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Mail Stop 4628 December 29, 2015 Via E -mail John F. Gehring Chief Financial Officer Conagra Foods, Inc. One Conagra Drive Omaha, NE 68102 Re: Conagra Foods, Inc. Form 10-K for Fiscal Year Ended May 31, 2015 Response Dated December 3, 2015 File No. 001 -07275 Dear Mr. Gehring : We have reviewed your December 3, 2015 response to our comment 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 these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comments a pply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our November 20, 2015 letter . Form 10 -K for Fiscal Year Ended May 31, 2015 Notes to Consolidated Financial Statements Note 7 – Investments in Joint Ventures, page 58 1. Your response to prior comment 2 states that the disposal of a controlling interest in your flour mil ling operations constituted a strategic shift that had a major impact on your operations and financial results as your milling operations were the last of your purely commodity -based operations. It does not appear that your response adequately explains the qualitative evidence support ing the presentation of discontinued operations pursuant to ASU 2014 -08. Please p rovide us with additional information regarding the qualitative factors considered by management in determining that this presentation was app ropriate . John F. Gehring Conagra Foods, Inc. December 29, 2015 Page 2 You may contact Sandy Eisen at (202) 551 -3864 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3311 with any other questions. Sincerely, /s/ Ethan Horowitz Ethan Horowitz Branch Chief Office of Natural Resources