SEC Comment Letter for MILLERKNOLL, INC. (MLKN) (CIK 0000066382) (MLKN) — Feb 27, 2014
MILLERKNOLL, INC. (MLKN) (CIK 0000066382)
Date: Feb. 27, 2014 · CIK: 0000066382 · Accession: 0000000000-14-009863
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 24, 2014
Letter
February 27, 2014 Via E -mail Mr. Gregory J. Bylsma Chief Financial Officer Herman Miller , Inc. 855 East Main Avenue Zeeland, MI 49464 -0302
Re: Herman Miller , Inc. Form 10 -K Filed July 30 , 2013 File No. 1-1514 1
Dear Mr. Bylsma :
We have reviewed your response dated February 13, 2014 and have the following comment .
Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing the information you pro vide in response to this comment , we may have additional comments.
Form 10 -K for the year ended June 1, 2013
Management’s Discussion and Analysis, page 15
Financial Results, page 20
1. We have read your response to comment 2 in our letter dated January 24, 2014 which includes proposed revisions to existing disclosure that indicates increases in “change in other volumes” is attributable to increases in North American Furniture Solutions and Specialty and Consumer segments. Your proposed disclosure as we ll as your segment discussion on page 27 does not provide detailed information regarding the factors that contributed to the increases. Given the “Change in other volumes” line item represents the largest aggregate impact of the change in net sales during each of the years presented, in future filings, please consider quantifying the factors that contributed to significant year over year volume increases .
Mr. Gregory J. Bylsma Herman Miller , Inc. February 27, 2014 Page 2
You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3854 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Melissa N. Rocha
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February 27, 2014 Via E -mail Mr. Gregory J. Bylsma Chief Financial Officer Herman Miller , Inc. 855 East Main Avenue Zeeland, MI 49464 -0302 Re: Herman Miller , Inc. Form 10 -K Filed July 30 , 2013 File No. 1-1514 1 Dear Mr. Bylsma : We have reviewed your response dated February 13, 2014 and have the following comment . Please respond to this letter within ten business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you pro vide in response to this comment , we may have additional comments. Form 10 -K for the year ended June 1, 2013 Management’s Discussion and Analysis, page 15 Financial Results, page 20 1. We have read your response to comment 2 in our letter dated January 24, 2014 which includes proposed revisions to existing disclosure that indicates increases in “change in other volumes” is attributable to increases in North American Furniture Solutions and Specialty and Consumer segments. Your proposed disclosure as we ll as your segment discussion on page 27 does not provide detailed information regarding the factors that contributed to the increases. Given the “Change in other volumes” line item represents the largest aggregate impact of the change in net sales during each of the years presented, in future filings, please consider quantifying the factors that contributed to significant year over year volume increases . Mr. Gregory J. Bylsma Herman Miller , Inc. February 27, 2014 Page 2 You may contact Jenn Do at (202) 551-3743 , or me at (202) 551 -3854 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Melissa N. Rocha Melissa N. Rocha Senior Assistant Chief Accountant