SEC Comment Letter for WOLVERINE WORLD WIDE (WWW) — Oct 4, 2006
WOLVERINE WORLD WIDE INC /DE/ (WWW) (CIK 0000110471)
Date: Oct. 4, 2006 · CIK: 0000110471 · Accession: 0000000000-06-048086
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 19, 2006, September 6, 2006
Letter
Mail Stop 3561 By Facsimile and U.S. Mail Mr. Timothy J. O’Donovan Chief Executive Officer Wolverine World Wide, Inc. 9341 Courtland Drive Rockford, Michigan 49351
Re: Form 10-K for the year ended December 31, 2005 Filed March 15, 2006 File No. 1-06024
Dear Mr. O’Donovan:
We reviewed your responses to our prior comments on the above referenced filing as set forth in your letter dated September 19, 2006 and have the following additional comments. Please provide a written response to our comments. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Form 10-K for the year ended December 31, 2005
Appendix A. Financial Statements
Consolidated Statements of Stockholders’ Equity and Comprehensive Income, page 2
1. We note your response to comment 1 in our letter dated September 6, 2006 and understand that the treasury shares were issued to fund a portion of your stock split. However, it is still unclear to us why your accounting treatment is appropriate under GAAP and why the charge to additional paid -in capital should represent the amount of prev ious repurchases over par value on the same class of stock. Please tell us what authoritative guidance supports your accounting
Mr. Timothy J. O’Donovan Wolverine World Wide, Inc. September 29, 2006 Page 2 treatment if paragraph 12 of APB 6 is not relevant by analogy. In addition, please tell us what the effect would be if you applied APB 6.
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provide any requested information. Detailed letters gr eatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please direct them to John Cannarella, Staff Accountant, at (202) 551-3337. In his absence, direct your questions to William Thompson at (202) 551-3334. Any other questions may be directed to me at (202) 551-3716.
Sincerely,
William Choi
A c c o u n t i n g B r a n c h C h i e f
Show Raw Text
September 29, 2006
Mail Stop 3561
By Facsimile and U.S. Mail
Mr. Timothy J. O’Donovan
Chief Executive Officer
Wolverine World Wide, Inc.
9341 Courtland Drive
Rockford, Michigan 49351
Re: Form 10-K for the year ended December 31, 2005
Filed March 15, 2006
File No. 1-06024
Dear Mr. O’Donovan:
We reviewed your responses to our prior comments on the above referenced filing
as set forth in your letter dated September 19, 2006 and have the following additional
comments. Please provide a written response to our comments. Please be as detailed as
necessary in your explanation. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
Form 10-K for the year ended December 31, 2005
Appendix A. Financial Statements
Consolidated Statements of Stockholders’ Equity and Comprehensive Income, page 2
1. We note your response to comment 1 in our letter dated September 6, 2006 and
understand that the treasury shares were issued to fund a portion of your stock
split. However, it is still unclear to us why your accounting treatment is
appropriate under GAAP and why the charge to additional paid -in capital should
represent the amount of prev ious repurchases over par value on the same class of
stock. Please tell us what authoritative guidance supports your accounting
Mr. Timothy J. O’Donovan
Wolverine World Wide, Inc. September 29, 2006
Page 2
treatment if paragraph 12 of APB 6 is not relevant by analogy. In addition, please
tell us what the effect would be if you applied APB 6.
Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our
comments and provide any requested information. Detailed letters gr eatly facilitate our
review. Please understand that we may have additional comments after reviewing your
responses to our comments.
If you have any questions regarding these comments, please direct them to John Cannarella, Staff Accountant, at (202) 551-3337. In his absence, direct your questions to
William Thompson at (202) 551-3334. Any other questions may be directed to me at
(202) 551-3716.
Sincerely,
William Choi
A c c o u n t i n g B r a n c h C h i e f