SEC Comment Letter for MCCORMICK & CO (MKC) — Jul 14, 2011
MCCORMICK & CO INC
Date: July 14, 2011 · CIK: 0000063754 · Accession: 0000000000-11-042777
AI Filing Summary & Sentiment
Referenced dates: June 15, 2011
Letter
July 14, 2011 Via Email Kenneth A. Kelly, Jr. Senior Vice President & Controller McCormick & Company, Incorporated 18 Loveton Circle Sparks, Maryland 21152
Re: McCormick & Company, Incorporated Form 10-K for Fiscal Year Ended November 30, 2010 Filed January 27, 2011 File No. 1-14920
Dear Mr. Kelly: We have reviewed your response letter dated June 15, 2011 and have the following comment. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comment applies to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended November 30, 2010
Exhibit 13
Note 16: Business Segments, page 55
1. We have considered your response to prior comment two and it appear s that each of the ten components identified in your “blue sh eets” represent an operating segment under ASC 280-10. Please revise your segment pres entation and disclosure, as appropriate.
Kenneth A. Kelly, Jr. McCormick & Company, Incorporated July 14, 2011 Page 2
You may contact Michael Fay at (202) 551-3812 or Mark Shannon at (202) 551-3299 if you have questions regarding the comment and rela ted matters. Please contact me with any other questions at (202) 551-3489.
Sincerely,
/s/ Ethan Horowitz for B r a d S k i n n e r Senior Assistant Chief Accountant
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July 14, 2011 Via Email Kenneth A. Kelly, Jr. Senior Vice President & Controller McCormick & Company, Incorporated 18 Loveton Circle Sparks, Maryland 21152 Re: McCormick & Company, Incorporated Form 10-K for Fiscal Year Ended November 30, 2010 Filed January 27, 2011 File No. 1-14920 Dear Mr. Kelly: We have reviewed your response letter dated June 15, 2011 and have the following comment. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comment applies to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended November 30, 2010 Exhibit 13 Note 16: Business Segments, page 55 1. We have considered your response to prior comment two and it appear s that each of the ten components identified in your “blue sh eets” represent an operating segment under ASC 280-10. Please revise your segment pres entation and disclosure, as appropriate. Kenneth A. Kelly, Jr. McCormick & Company, Incorporated July 14, 2011 Page 2 You may contact Michael Fay at (202) 551-3812 or Mark Shannon at (202) 551-3299 if you have questions regarding the comment and rela ted matters. Please contact me with any other questions at (202) 551-3489. Sincerely, /s/ Ethan Horowitz for B r a d S k i n n e r Senior Assistant Chief Accountant