SEC Comment Letter for COOPER COMPANIES, INC. (COO) (CIK 0000711404) (COO) — Feb 23, 2017
COOPER COMPANIES, INC. (COO) (CIK 0000711404)
Date: Feb. 23, 2017 · CIK: 0000711404 · Accession: 0000000000-17-006215
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3030 February 2 3, 2017 Via E -mail Mr. Albert G. White, III Execut ive Vice President and Chief Financial Officer The Cooper Companies, Inc. 6140 Stoneridge Mall Road, Suite 590 Pleasanton, California 94588
Re: The Cooper Companies, Inc. Form 10-K for the Fiscal Year Ended October 31 , 2016 Filed December 22, 2016 Form 8 -K filed December 8, 2016 File No. 001 -08597
Dear Mr. White :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment s. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to th ese comment s 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 s apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to th ese comment s, we may have additional comments.
Form 8 -K filed December 8, 2016
Exhibit 99 .1
1. You disclose non -GAAP gross margin and operating margin on pages 1 to 3. In future filings when you present a non -GAAP measure please include a reconciliation to the most directly comparable financial measure presented in accordance with GAAP as required by Item 10(e)(B) of Regulation S -K.
2. We note that you present GAAP EPS and non -GAAP EPS on pages 1 to 3 of your earnings release. Please revise f uture earnings releases to indicate whether these amounts represent basic or diluted earnings per share.
Alber t G. White, III The Cooper Companies, Inc. February 2 3, 2017 Page 2
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 Julie Sherman at (202) 551 -3640 or me at (202) 551 -3676 with any questions. You may also reach Martin James, Senior Assistant Chief Accountant, at (202) 551 -3671.
Sincerely,
/s/ Brian Cascio
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Mail Stop 3030
February 2 3, 2017
Via E -mail
Mr. Albert G. White, III
Execut ive Vice President and Chief Financial Officer
The Cooper Companies, Inc.
6140 Stoneridge Mall Road, Suite 590
Pleasanton, California 94588
Re: The Cooper Companies, Inc.
Form 10-K for the Fiscal Year Ended October 31 , 2016
Filed December 22, 2016
Form 8 -K filed December 8, 2016
File No. 001 -08597
Dear Mr. White :
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment s. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to th ese comment s 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 s apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to th ese comment s, we may have additional comments.
Form 8 -K filed December 8, 2016
Exhibit 99 .1
1. You disclose non -GAAP gross margin and operating margin on pages 1 to 3. In future
filings when you present a non -GAAP measure please include a reconciliation to the
most directly comparable financial measure presented in accordance with GAAP as
required by Item 10(e)(B) of Regulation S -K.
2. We note that you present GAAP EPS and non -GAAP EPS on pages 1 to 3 of your
earnings release. Please revise f uture earnings releases to indicate whether these amounts
represent basic or diluted earnings per share.
Alber t G. White, III
The Cooper Companies, Inc.
February 2 3, 2017
Page 2
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 Julie Sherman at (202) 551 -3640 or me at (202) 551 -3676 with any
questions. You may also reach Martin James, Senior Assistant Chief Accountant, at (202) 551 -3671.
Sincerely,
/s/ Brian Cascio
Brian Cascio
Accounting Branch Chief
Office of Electronics and Machinery