SEC Comment Letter for MILLERKNOLL, INC. (MLKN) (CIK 0000066382) (MLKN) — Mar 2, 2017
MILLERKNOLL, INC. (MLKN) (CIK 0000066382)
Date: March 2, 2017 · CIK: 0000066382 · Accession: 0000000000-17-006979
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 3, 2017
Letter
Mail Stop 4631 March 2 , 2017 Via E -mail Mr. Jeffrey M. Stutz Chief Financial Officer Herman Miller , Inc. 855 East Main Ave Zeeland, MI 49464
Re: Herman Miller , Inc. Form 10-K Filed July 2 6, 2016 File No. 1-15141
Dear Mr. Stutz :
We have read your response dated February 17, 2017, and have the following comment .
Please respond to this letter within ten business days by providing the requested information, or advise us as soon as possible when you will respond. If you do n ot believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments.
Form 10 -K for the year ended May 28, 2016
Controls and Procedures, page 82
1. We have read your response to comment 2 in our letter dated February 3, 2017. You indicate that the ERP implementation at DWR did not materially affect your internal controls over finan cial reporting nor did it result in a material change in internal controls over financial reporting. However, based on your response and notwithstanding that the order disruptions resulting from the implementation may not have impacted your evaluation of t he effectiveness of the related controls, it is unclear to us how the actual implementation of the ERP would not constitute a material change in internal control over financial reporting during the quarter ended November 28, 2015. Please tell us if an ERP system was already implemented or is being implemented in other business units, if the current ERP implementation only impacts DWR, confirm that the business disruption only related to DWR and tell us how you considered all of these factors in determining that the implementation of the ERP system does not constitute a material change in internal control over financial reporting under Item 308(c) of Regulation S -K.
Mr. Jeffrey M. Stutz Herman Miller, Inc. March 2, 2017 Page 2
We remind you that the company and its management are responsible for the accuracy and adequac y of their disclosures, notwithstanding any review, comments, action or absence of action by the staff .
You may contact Jenn Do at (202) 551-3743 or me a t (202) 551 -3854 with any questions.
Sincerely,
/s/ Melissa N. Rocha
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Mail Stop 4631 March 2 , 2017 Via E -mail Mr. Jeffrey M. Stutz Chief Financial Officer Herman Miller , Inc. 855 East Main Ave Zeeland, MI 49464 Re: Herman Miller , Inc. Form 10-K Filed July 2 6, 2016 File No. 1-15141 Dear Mr. Stutz : We have read your response dated February 17, 2017, and have the following comment . Please respond to this letter within ten business days by providing the requested information, or advise us as soon as possible when you will respond. If you do n ot believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 10 -K for the year ended May 28, 2016 Controls and Procedures, page 82 1. We have read your response to comment 2 in our letter dated February 3, 2017. You indicate that the ERP implementation at DWR did not materially affect your internal controls over finan cial reporting nor did it result in a material change in internal controls over financial reporting. However, based on your response and notwithstanding that the order disruptions resulting from the implementation may not have impacted your evaluation of t he effectiveness of the related controls, it is unclear to us how the actual implementation of the ERP would not constitute a material change in internal control over financial reporting during the quarter ended November 28, 2015. Please tell us if an ERP system was already implemented or is being implemented in other business units, if the current ERP implementation only impacts DWR, confirm that the business disruption only related to DWR and tell us how you considered all of these factors in determining that the implementation of the ERP system does not constitute a material change in internal control over financial reporting under Item 308(c) of Regulation S -K. Mr. Jeffrey M. Stutz Herman Miller, Inc. March 2, 2017 Page 2 We remind you that the company and its management are responsible for the accuracy and adequac y of their disclosures, notwithstanding any review, comments, action or absence of action by the staff . You may contact Jenn Do at (202) 551-3743 or me a t (202) 551 -3854 with any questions. Sincerely, /s/ Melissa N. Rocha Melissa N. Rocha Senior Assistant Chief Accountant Office of Manufacturing and Construction