SEC Comment Letter for HEICO (HEI) — May 14, 2014

HEICO CORP
Date: May 14, 2014 · CIK: 0000046619 · Accession: 0000000000-14-024603

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AI Filing Summary & Sentiment

File numbers found in text: 001-04604

Date

May 14, 2014

Author

/s/ Linda Cvrkel

Form

UPLOAD

Company

HEICO CORP

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE May 14, 2014 Via E-mail Carlos L. Macau, Jr. Chief Financial Officer HEICO Corporation 3000 Taft Street Hollywood, Florida 33021

Re: HEICO Corporation Form 10-K for the Fiscal Year E nded Octo ber 31, 201 3 Filed December 19 , 201 3 File No. 001-04604

Dear Mr. Macau :

We have completed our review of your filings. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Linda Cvrkel

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

        May 14, 2014

Via E-mail
Carlos L. Macau, Jr.
Chief Financial Officer
HEICO  Corporation
3000 Taft Street
Hollywood, Florida 33021

Re: HEICO  Corporation
 Form 10-K for the Fiscal Year E nded Octo ber 31, 201 3
Filed  December 19 , 201 3
 File No.  001-04604

Dear Mr. Macau :

We have completed our review of your filings.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

/s/ Linda Cvrkel

Linda Cvrkel
Branch Chief

SecProbe.io