SEC Comment Letter for HAWKINS INC (HWKN) (CIK 0000046250) (HWKN) — Apr 16, 2007
HAWKINS INC (HWKN) (CIK 0000046250)
Date: April 16, 2007 · CIK: 0000046250 · Accession: 0000000000-07-018595
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 5, 2007
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE April 16, 2007 By U.S. mail and facsimile to (612) 331-5304 Mr. Marvin E. Dee Chief Financial Officer Hawkins, Inc. 3100 East Hennepin Avenue Minneapolis, MN 55413 RE: Hawkins, Inc. Form 10-K for the fiscal year ended April 2, 2006 Filed June 16, 2006 File No. 0-7647
Dear Mr. Dee: We have reviewed your response letter dated April 5, 2007 and have the following additional comments. If you disagree , we will consider your explanation as to why our comment is inapplicable. After revi ewing this information, we may or may not raise additional comments. Form 10-K for the year ended April 2, 2006
Litigation Settlement, page 12
1. In future filings please provide a more comprehensive discussion concerning settlements through the receipt of shares from the former principals of an acquisition target, so that readers ca n understand your accounting treatment and classification in a more transparent manner. It may also be material to know that the selling of those shares on the open ma rket may have had a significant adverse impact on your trading price due to the low average daily trading volume of your stock. Notification of Late Filing, February 8, 2007
2. We have read your response to comme nt 6 in our letter da ted March 8, 2007. You indicate that your chief executive officer and chief financial o fficer are currently evaluating the operating effectiveness of your disclosure controls and procedures for the fiscal third quarter ended December 31, 2006.
Mr. Marvin E. Dee Hawkins, Inc. April 16, 2007 Page 2 We note that you anticipate such fili ng to be in May of 2007, and you have experienced numerous difficulties. We urge you to carefully consider the definition of effectiveness of disclosu re controls and procedures in your assessment and the whether this represents a material weakness. We may have further comments when the December 31, 2006 Form 10-Q is filed.
* * * *
As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Jenn Do at (202) 551-3743, or me at (202) 551-3689 if you have questions regarding these comments.
S i n c e r e l y ,
John M. Hartz S e n i o r A s s i s t a n t C h i e f Accountant
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
April 16, 2007
By U.S. mail and facsimile to (612) 331-5304
Mr. Marvin E. Dee Chief Financial Officer Hawkins, Inc. 3100 East Hennepin Avenue Minneapolis, MN 55413
RE: Hawkins, Inc.
Form 10-K for the fiscal year ended April 2, 2006
Filed June 16, 2006 File No. 0-7647
Dear Mr. Dee:
We have reviewed your response letter dated April 5, 2007 and have the
following additional comments. If you disagree , we will consider your explanation as to
why our comment is inapplicable. After revi ewing this information, we may or may not
raise additional comments. Form 10-K for the year ended April 2, 2006
Litigation Settlement, page 12
1. In future filings please provide a more comprehensive discussion concerning
settlements through the receipt of shares from the former principals of an acquisition target, so that readers ca n understand your accounting treatment and
classification in a more transparent manner. It may also be material to know that
the selling of those shares on the open ma rket may have had a significant adverse
impact on your trading price due to the low average daily trading volume of your
stock.
Notification of Late Filing, February 8, 2007
2. We have read your response to comme nt 6 in our letter da ted March 8, 2007. You
indicate that your chief executive officer and chief financial o fficer are currently
evaluating the operating effectiveness of your disclosure controls and procedures
for the fiscal third quarter ended December 31, 2006.
Mr. Marvin E. Dee
Hawkins, Inc. April 16, 2007 Page 2
We note that you anticipate such fili ng to be in May of 2007, and you have
experienced numerous difficulties. We urge you to carefully consider the
definition of effectiveness of disclosu re controls and procedures in your
assessment and the whether this represents a material weakness. We may have
further comments when the December 31, 2006 Form 10-Q is filed.
* * * *
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Please furnish a letter that keys your
responses to our comments and provides any requested supplemental information.
Detailed response letters greatly facilitate our review. Please file your response letter on
EDGAR. Please understand that we may have additional comments after reviewing your
responses to our comments.
You may contact Jenn Do at (202) 551-3743, or me at (202) 551-3689 if you have
questions regarding these comments.
S i n c e r e l y ,
John M. Hartz S e n i o r A s s i s t a n t C h i e f Accountant