SEC Comment Letter for SYSCO CORP (SYY) (CIK 0000096021) (SYY) — May 8, 2007
SYSCO CORP (SYY) (CIK 0000096021)
Date: May 8, 2007 · CIK: 0000096021 · Accession: 0000000000-07-022852
AI Filing Summary & Sentiment
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-0405 DIVISION OF CORPORATION FINANCE Mail Stop 3561 May 8, 2007 Mr. John K. Stubblefield, Jr. Executive Vice President, Finance & Chief Financial Officer Sysco Corporation 1390 Enclave Parkway Houston, Texas 77077-2099
Re: Sysco Corporation Item 4.02 Form 8-K Filed May 7, 2007 File No. 1-6544
Dear Mr. Stubblefield:
We have reviewed your filing and have the following comment. We think you should revise your disclosures in future filin gs in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In our comment, we may ask you to provide us with more information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 8-K filed May 7, 2007
1. In light of the restatements please confir m to us that your officers’ reconsidered their conclusions regarding the effec tiveness of disclosu re controls and procedures for the quarterly periods ended September 30, 2006 and December 30, 2006. In future filings, when you amend your periodic reports to file restated financial statements, describe the eff ect of the restatement on the officers’ conclusions regarding the eff ectiveness of disclosure cont rols and procedures. If the officers’ conclude that disclosure controls and pr ocedures were effective,
Mr. John K. Stubblefield, Jr. Sysco Corporation May 8, 2007 Page 2 despite the restatement, describe the basi s for the officers’ conclusions. See Item 307 of Regulation S-K.
Please respond to these comments within 5 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested information. Detailed letters gr eatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comment. Please su bmit your response letter on EDGAR.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosu re in response to staff comments do not foreclose the Commission from ta king any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commissi on or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comment on your filing.
If you have any questions regarding this co mment, please direct them to me at (202) 551-3336. In my absence, you may di rect your questions to William Thompson, Branch Chief, at (202) 551-3344.
Sincerely,
Adam Phippen
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405
DIVISION OF
CORPORATION FINANCE
Mail Stop 3561
May 8, 2007
Mr. John K. Stubblefield, Jr.
Executive Vice President, Finance & Chief Financial Officer
Sysco Corporation
1390 Enclave Parkway
Houston, Texas 77077-2099
Re: Sysco Corporation
Item 4.02 Form 8-K
Filed May 7, 2007
File No. 1-6544
Dear Mr. Stubblefield:
We have reviewed your filing and have the following comment. We think you
should revise your disclosures in future filin gs in response to this comment. If you
disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In our
comment, we may ask you to provide us with more information so we may better understand your disclosure. After reviewing th is information, we may raise additional
comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 8-K filed May 7, 2007
1. In light of the restatements please confir m to us that your officers’ reconsidered
their conclusions regarding the effec tiveness of disclosu re controls and
procedures for the quarterly periods ended September 30, 2006 and December 30,
2006. In future filings, when you amend your periodic reports to file restated financial statements, describe the eff ect of the restatement on the officers’
conclusions regarding the eff ectiveness of disclosure cont rols and procedures. If
the officers’ conclude that disclosure controls and pr ocedures were effective,
Mr. John K. Stubblefield, Jr.
Sysco Corporation May 8, 2007
Page 2
despite the restatement, describe the basi s for the officers’ conclusions. See Item
307 of Regulation S-K.
Please respond to these comments within 5 business days or tell us when you will
provide us with a response. Please furnish a letter that keys your response to our
comment and provides any requested information. Detailed letters gr eatly facilitate our
review. Please understand that we may have additional comments after reviewing your
responses to our comment. Please su bmit your response letter on EDGAR.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosu re in response to staff comments do
not foreclose the Commission from ta king any action with respect to the
filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
If you have any questions regarding this co mment, please direct them to me at
(202) 551-3336. In my absence, you may di rect your questions to William Thompson,
Branch Chief, at (202) 551-3344.
Sincerely,
Adam Phippen
Mr. John K. Stubblefield, Jr.
Sysco Corporation May 8, 2007
Page 3