SEC Comment Letter for COOPER COMPANIES, INC. (COO) (CIK 0000711404) (COO) — Jul 19, 2011
COOPER COMPANIES, INC. (COO) (CIK 0000711404)
Date: July 19, 2011 · CIK: 0000711404 · Accession: 0000000000-11-043650
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08597
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE July 19, 2011 Via E-mail Mr. Eugene J. Midlock Chief Financial Officer The Cooper Companies, Inc. 6140 Stoneridge Mall Road Suite 590 Pleasanton, CA 94588 Re: The Cooper Companies, Inc. Form 10-Q for the quarterly period ending January 31, 2011 Filed March 4, 2011 File No. 001-08597
Dear Mr. Midlock: We have reviewed your response dated July 14, 2011 and related filings and have the following comments. In some of our co mments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstan ces, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments.
Mr. Eugene J. Midlock The Cooper Companies, Inc. July 19, 2011 Page 2 Form 10-Q for the quarterly period ending January 31, 2011
Financial Statements, page 3
Note 2. Acquisition and Rest ructuring Costs, page 9
1. We note your response to our prior co mment 3. However, it appears that correcting the error in the period in wh ich it originated would be quantitatively significant to that period. Gi ven that fact, please provide us with the detailed SAB 99 and SAB 108 analysis supporting your c onclusion that the correction of the error would not be material to th e period in which it originated.
You may contact Leigh Ann Schultz at (202) 551-3628 or Kate Tillan at (202) 551-3604 if you have questions regarding these comments. You may also contact me at (202) 551-3671 with an y other questions.
Sincerely, /s/ Martin James
Martin James Senior Assistant Chief Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
July 19, 2011
Via E-mail
Mr. Eugene J. Midlock Chief Financial Officer The Cooper Companies, Inc. 6140 Stoneridge Mall Road Suite 590 Pleasanton, CA 94588
Re: The Cooper Companies, Inc.
Form 10-Q for the quarterly period ending January 31, 2011
Filed March 4, 2011 File No. 001-08597
Dear Mr. Midlock:
We have reviewed your response dated July 14, 2011 and related filings and have
the following comments. In some of our co mments, we may ask you to provide us with
information so we may better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstan ces, please tell us why in
your response.
After reviewing the information you provide in response to these comments, we
may have additional comments.
Mr. Eugene J. Midlock
The Cooper Companies, Inc. July 19, 2011 Page 2
Form 10-Q for the quarterly period ending January 31, 2011
Financial Statements, page 3
Note 2. Acquisition and Rest ructuring Costs, page 9
1. We note your response to our prior co mment 3. However, it appears that
correcting the error in the period in wh ich it originated would be quantitatively
significant to that period. Gi ven that fact, please provide us with the detailed SAB
99 and SAB 108 analysis supporting your c onclusion that the correction of the
error would not be material to th e period in which it originated.
You may contact Leigh Ann Schultz at (202) 551-3628 or Kate Tillan at (202)
551-3604 if you have questions regarding these comments. You may also contact me at
(202) 551-3671 with an y other questions.
Sincerely, /s/ Martin James
Martin James Senior Assistant Chief Accountant