SEC Company Response from BRINKER INTERNATIONAL, INC (EAT) (CIK 0000703351) (EAT) — Dec 21, 2004
BRINKER INTERNATIONAL, INC (EAT) (CIK 0000703351)
Date: Dec. 21, 2004 · CIK: 0000703351 · Accession: 0000703351-04-000107
AI Filing Summary & Sentiment
Referenced dates: November 30, 2004
Letter
Division of Corporate Finance Securities and Exchange Commission Washington, D.C. 20549 Form 10-K for the year ended June 30, 2004 Commission file #: 1-10275
RE: Brinker International
Dear Mr. Humphrey:
The purpose of this letter is to confirm our understanding of the resolution to your questions set forth in your letter dated November 30, 2004 and further discussed with you on our conference call on December 17, 2004.
We confirm that we believe it would have been more appropriate to expense the purchase price of the intangible franchise rights acquired in fiscal 1998. As such, the $4.4 million intangible asset will be recorded as an adjustment to retained earnings in an amended Form 10-K for the year ended June 30, 2004 and an amended Form 10-Q for the period ended September 29, 2004.
We acknowledge that we are responsible for the adequacy and accuracy of the disclosure in the filings; staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and we may not assert staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States.
If you have any additional questions please feel free to contact me at 972-770-9406.
Sincerely,
Charles
M. Sonsteby
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CORRESP
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Response Letter
December 21, 2004
Mr. David R. Humphrey
Branch Chief
Division of Corporate Finance
Securities and Exchange
Commission
Washington, D.C. 20549
RE: Brinker International
Form
10-K for the year ended June 30, 2004
Commission
file #: 1-10275
Dear Mr. Humphrey:
The purpose of this letter is to
confirm our understanding of the resolution to your questions set forth in your
letter dated November 30, 2004 and further discussed with you on our conference
call on December 17, 2004.
We confirm that we believe it
would have been more appropriate to expense the purchase price of the
intangible franchise rights acquired in fiscal 1998. As such, the $4.4 million intangible asset will be recorded as an
adjustment to retained earnings in an amended Form 10-K for the year ended June
30, 2004 and an amended Form 10-Q for the period ended September 29, 2004.
We acknowledge that we are
responsible for the adequacy and accuracy of the disclosure in the filings;
staff comments or changes to disclosure in response to staff comments in the
filings reviewed by the staff do not foreclose the Commission from taking any
action with respect to the filing; and we may not assert staff comments as a
defense in any proceedings initiated by the Commission or any person under the
federal securities laws of the United States.
If you have any additional
questions please feel free to contact me at 972-770-9406.
Sincerely,
Charles
M. Sonsteby
Executive
Vice President and Chief
Financial
Officer