SEC Company Response from NBTY INC (CIK 0000070793) — Nov 18, 2005
NBTY INC (CIK 0000070793)
Date: Nov. 18, 2005 · CIK: 0000070793 · Accession: 0001104659-05-056775
AI Filing Summary & Sentiment
Letter
United States Securities and Division of Corporation Finance United States Securities and Division of Corporation Finance 450 Fifth Street, N.W. Washington, DC 20549-0801 Re: NBTY, Inc. (“NBTY” or the “Company”) - File No. 1-31788
Dear Mr. Rosenberg and Mr. Sherman:
In accordance with my phone conversation with Todd Sherman on November 8, 2005 please be advised that NBTY confirms that it will incorporate the following information in future filings:
1. The Company will separately disclose the rollforward schedule of the promotional program incentive accrual (including all customer charges which were recorded directly against sales) within the Management’s Discussion and Analysis Section.
2. The Company will disclose the underlying information regarding the nature of the amounts charged to other accounts in the promotional program incentive accrual in fiscal year 2003 within the Schedule II “Valuation and Qualifying Accounts”.
Please let me know if you have any questions. We appreciate your comments and would be pleased to discuss these matters further at your request.
Sincerely,
/s/ Harvey Kamil
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CORRESP 1 filename1.htm November 18, 2005 Mr. Jim B. Rosenberg United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, DC 20549-0801 Mr. Todd Sherman United States Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, DC 20549-0801 Re: NBTY, Inc. (“NBTY” or the “Company”) - File No. 1-31788 Dear Mr. Rosenberg and Mr. Sherman: In accordance with my phone conversation with Todd Sherman on November 8, 2005 please be advised that NBTY confirms that it will incorporate the following information in future filings: 1. The Company will separately disclose the rollforward schedule of the promotional program incentive accrual (including all customer charges which were recorded directly against sales) within the Management’s Discussion and Analysis Section. 2. The Company will disclose the underlying information regarding the nature of the amounts charged to other accounts in the promotional program incentive accrual in fiscal year 2003 within the Schedule II “Valuation and Qualifying Accounts”. Please let me know if you have any questions. We appreciate your comments and would be pleased to discuss these matters further at your request. Sincerely, /s/ Harvey Kamil Harvey Kamil President and Chief Financial Officer