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SEC Comment Letter for UNIFIRST CORP (UNF) (CIK 0000717954) (UNF) — Aug 2, 2006

UNIFIRST CORP (UNF) (CIK 0000717954)
Date: Aug. 2, 2006 · CIK: 0000717954 · Accession: 0000000000-06-036334

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-08504

Referenced dates: August 22, 2005, February 18, 2005

Date
September 22, 2005
Author
Larry Spirgel
Form
UPLOAD
Company
UNIFIRST CORP (UNF) (CIK 0000717954)

Letter

Mail Stop 3561 September 22, 2005 Via U.S. Mail and Fax (978-988-0659) John B. Bartlett Chief Financial Officer UniFirst Corporation 68 Jonspin Road Wilmington, MA 01887

Re: UniFirst Corporation Form 10-K/A for the fiscal year ended August 28, 2004 Filed July 28, 2005 File No. 001-08504

Dear Mr. Bartlett:

We have reviewed your supplemental response letter dated August 22, 2005 as well as the above referenced filing and have the following comments. As noted in our comment letter dated February 18, 2005, we have limited our review to your financial statements and related disclosures and will make no further review of your documents. Where indicated, we think you should revise your documents in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

Form10-K/A for the fiscal year ended August 28, 2004

Item 9A Controls and Procedures

1. In light of the fact that you restated the financial statements for the period ending August 28, 2004, we believe the principal executive and principal financial officers need to re-evaluate their original conclusions surrounding the effectiveness of their disclosure controls and procedures (DCP) as of the end of the period covered by the original report. At a minimum, we expect disclosure explaining that Company`s management continues to believe the DCP were effective and why the principal executive and principal financial officers continue to believe the DCP were effective, after considering the fact that the financial statements were required to be restated. In addition, if applicable, the company should disclose pursuant to Item 308(c) of Regulation S-K and Exchange Act Rule 12b- 20 what has been done to correct the internal control problems.

* * * *

As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

You may contact Joe Cascarano, Staff Accountant, at (202) 551- 3376 or Carlos Pacho, Senior Assistant Chief Accountant, at (202) 551-3835 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551- with any other questions.

Sincerely,
Larry Spirgel
Assistant Director

Show Raw Text
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Mail Stop 3561

      							September 22, 2005

Via U.S. Mail and Fax (978-988-0659)
John B. Bartlett
Chief Financial Officer
UniFirst Corporation
68 Jonspin Road
Wilmington, MA  01887

	Re:	UniFirst Corporation
		Form 10-K/A for the fiscal year ended August 28, 2004
		Filed July 28, 2005
File No. 001-08504

Dear Mr. Bartlett:

We have reviewed your supplemental response letter dated August
22,
2005 as well as the above referenced filing and have the following
comments.  As noted in our comment letter dated February 18, 2005,
we
have limited our review to your financial statements and related
disclosures and will make no further review of your documents.
Where
indicated, we think you should revise your documents in response
to
these comments.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
We welcome any questions you may have about our comments or any
other
aspect of our review.  Feel free to call us at the telephone
numbers
listed at the end of this letter.

Form10-K/A for the fiscal year ended August 28, 2004

Item 9A Controls and Procedures

1. In light of the fact that you restated the financial statements
for the period ending August 28, 2004, we believe the principal
executive and principal financial officers need to re-evaluate
their
original conclusions surrounding the effectiveness of their
disclosure controls and procedures (DCP) as of the end of the
period
covered by the original report. At a minimum, we expect disclosure
explaining that Company`s management continues to believe the DCP
were effective and why the principal executive and principal
financial officers continue to believe the DCP were effective,
after
considering the fact that the financial statements were required
to
be restated. In addition, if applicable, the company should
disclose
pursuant to Item 308(c) of Regulation S-K and Exchange Act Rule
12b-
20 what has been done to correct the internal control problems.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

      You may contact Joe Cascarano, Staff Accountant, at (202)
551-
3376 or Carlos Pacho, Senior Assistant Chief Accountant, at (202)
551-3835 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3810
with any other questions.

								Sincerely,

								Larry Spirgel
								Assistant Director

John B. Bartlett
UniFirst Corporation
September 22, 2005
Page 1

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