SEC Comment Letter for MILLERKNOLL, INC. (MLKN) (CIK 0000066382) (MLKN) — Jan 30, 2012
MILLERKNOLL, INC. (MLKN) (CIK 0000066382)
Date: Jan. 30, 2012 · CIK: 0000066382 · Accession: 0000000000-12-004901
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January 30, 2012 Via E-mail Mr. Gregory J. Bylsma Chief Financial Officer Herman Miller, Inc. 855 East Main Avenue Zeeland, Michigan 49464 RE: Herman Miller, Inc. Form 10-K for the Year ended May 28, 2011 Filed July 26, 2011 Form 10-Q for the Period ended December 3, 2011 Filed January 11, 2012 Response dated January 20, 2012 File No. 1-15141
Dear Mr. Bylsma: We have reviewed your response letter da ted January 20, 2012 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 this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10-Q for the Period ended December 3, 2011
Management’s Discussion and Analysis
Reportable Operating Segments, page 20 1. Your current segment discussion appears to on ly discuss the three months ended December 3, 2011 compared to the three months ended N ovember 27, 2010. There does not appear to be a segment discussion for the six months ended December 3, 2011 compared to the six months ended November 27, 2010. In future filings, please also provide a segment discussion for the cumulative year-to-date peri od compared to the prior year corresponding period. Please show us in your supplementa l response what the revisions will look like.
Mr. Gregory J. Bylsma Herman Miller, Inc. January 30, 2012 Page 2
If you have any questions regarding these comm ents, please direct them to Nudrat Salik, Staff Accountant, at (202) 551-3692 or, in her absence, to the undersigned at (202) 551-3769. S i n c e r e l y , / s / R u f u s D e c k e r Rufus Decker Accounting Branch Chief
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January 30, 2012
Via E-mail
Mr. Gregory J. Bylsma Chief Financial Officer Herman Miller, Inc. 855 East Main Avenue Zeeland, Michigan 49464
RE: Herman Miller, Inc.
Form 10-K for the Year ended May 28, 2011
Filed July 26, 2011
Form 10-Q for the Period ended December 3, 2011 Filed January 11, 2012 Response dated January 20, 2012 File No. 1-15141
Dear Mr. Bylsma:
We have reviewed your response letter da ted January 20, 2012 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 this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circum stances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
Form 10-Q for the Period ended December 3, 2011
Management’s Discussion and Analysis
Reportable Operating Segments, page 20
1. Your current segment discussion appears to on ly discuss the three months ended December
3, 2011 compared to the three months ended N ovember 27, 2010. There does not appear to
be a segment discussion for the six months ended December 3, 2011 compared to the six
months ended November 27, 2010. In future filings, please also provide a segment
discussion for the cumulative year-to-date peri od compared to the prior year corresponding
period. Please show us in your supplementa l response what the revisions will look like.
Mr. Gregory J. Bylsma Herman Miller, Inc. January 30, 2012 Page 2
If you have any questions regarding these comm ents, please direct them to Nudrat Salik,
Staff Accountant, at (202) 551-3692 or, in her absence, to the undersigned at (202) 551-3769.
S i n c e r e l y , / s / R u f u s D e c k e r
Rufus Decker
Accounting Branch Chief