SEC Comment Letter for Spectrum Brands Holdings, Inc. (SPB) (CIK 0000109177) (SPB) — Feb 27, 2020
Spectrum Brands Holdings, Inc. (SPB) (CIK 0000109177)
Date: Feb. 27, 2020 · CIK: 0000109177 · Accession: 0000000000-20-001762
AI Filing Summary & Sentiment
File numbers found in text: 001-04219
Letter
February 27, 2020 Jeremy W. Smeltser Chief Financial Officer Spectrum Brands Holdings, Inc. 3001 Deming Way Middleton, WI 53562 Re:Spectrum Brands Holdings, Inc. Form 10-K for the Fiscal Year Ended September 30, 2019 Filed November 15, 2019 Form 8-K Filed January 30, 2020 File No. 001-04219 Dear Mr. Smeltser: We have reviewed your filings and have the following comment. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 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 8-K Filed January 30, 2020 Exhibit 99.1, page 1 1.In future filings, please revise your bullet point highlights and the discussion in the second paragraph to also present the corresponding GAAP measure related to Adjusted EBITDA with equal or greater prominence. Please refer to Question 102.10 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. 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.
FirstName LastNameJeremy W. Smeltser Comapany NameSpectrum Brands Holdings, Inc. February 27, 2020 Page 2 FirstName LastName Jeremy W. Smeltser Spectrum Brands Holdings, Inc. February 27, 2020 Page 2 You may contact Dale Welcome at 202-551-3865 or Martin James, Senior Advisor, at 202-551-3671 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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February 27, 2020
Jeremy W. Smeltser
Chief Financial Officer
Spectrum Brands Holdings, Inc.
3001 Deming Way
Middleton, WI 53562
Re:Spectrum Brands Holdings, Inc.
Form 10-K for the Fiscal Year Ended September 30, 2019
Filed November 15, 2019
Form 8-K Filed January 30, 2020
File No. 001-04219
Dear Mr. Smeltser:
We have reviewed your filings and have the following comment. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this comment 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
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 8-K Filed January 30, 2020
Exhibit 99.1, page 1
1.In future filings, please revise your bullet point highlights and the discussion in the second
paragraph to also present the corresponding GAAP measure related to Adjusted EBITDA
with equal or greater prominence. Please refer to Question 102.10 of the Compliance and
Disclosure Interpretations on Non-GAAP Financial Measures.
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.
FirstName LastNameJeremy W. Smeltser
Comapany NameSpectrum Brands Holdings, Inc.
February 27, 2020 Page 2
FirstName LastName
Jeremy W. Smeltser
Spectrum Brands Holdings, Inc.
February 27, 2020
Page 2
You may contact Dale Welcome at 202-551-3865 or Martin James, Senior Advisor, at
202-551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing