SEC Comment Letter for WD 40 CO (WDFC) (CIK 0000105132) (WDFC) — Mar 12, 2020
WD 40 CO (WDFC) (CIK 0000105132)
Date: March 12, 2020 · CIK: 0000105132 · Accession: 0000000000-20-002245
AI Filing Summary & Sentiment
File numbers found in text: 000-06936
Letter
March 12, 2020 Jay Rembolt Chief Financial Officer WD 40 CO 9715 Businesspark Avenue San Diego, CA. 92131 Re:WD 40 CO Form 10-K for the year ended December 31, 2019 Filed on October 22, 2019 File No. 000-06936 Dear Mr. Rembolt: We have reviewed your filing 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the year ended August 31, 2019 Note 10. Revenue Recognition, page F-20 1.You indicate that you estimate your transaction price using the most likely method. Please tell us why it is appropriate to apply this method rather than the expected value method given the characteristics of your contracts and the nature of your promotional activities. See ASC 606-10-32-8. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Ameen Hamady at 202-551-3891, or in his absence, Terence O Brien at 202-551-3355 at if you have any questions.
FirstName LastNameJay Rembolt Comapany NameWD 40 CO March 12, 2020 Page 2 FirstName LastName Jay Rembolt WD 40 CO March 12, 2020 Page 2 Sincerely, Division of Corporation Finance Office of Life Sciences
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March 12, 2020
Jay Rembolt
Chief Financial Officer
WD 40 CO
9715 Businesspark Avenue
San Diego, CA. 92131
Re:WD 40 CO
Form 10-K for the year ended December 31, 2019
Filed on October 22, 2019
File No. 000-06936
Dear Mr. Rembolt:
We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the year ended August 31, 2019
Note 10. Revenue Recognition, page F-20
1.You indicate that you estimate your transaction price using the most likely method. Please
tell us why it is appropriate to apply this method rather than the expected value method
given the characteristics of your contracts and the nature of your promotional activities.
See ASC 606-10-32-8.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Ameen Hamady at 202-551-3891, or in his absence, Terence O Brien at
202-551-3355 at if you have any questions.
FirstName LastNameJay Rembolt
Comapany NameWD 40 CO
March 12, 2020 Page 2
FirstName LastName
Jay Rembolt
WD 40 CO
March 12, 2020
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences