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SEC Comment Letter for UNIFIRST CORP (UNF) (CIK 0000717954) (UNF) — Apr 13, 2009

UNIFIRST CORP (UNF) (CIK 0000717954)
Date: April 13, 2009 · CIK: 0000717954 · Accession: 0000000000-09-019157

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File numbers found in text: 000-08504

Referenced dates: April 3, 2009, March 5, 2009

Date
April 13, 2009
Author
Larry Spirgel
Form
UPLOAD
Company
UNIFIRST CORP (UNF) (CIK 0000717954)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549

DIVISION OF CORPORATION FINANCE

Mail Stop 3720 April 13, 2009 Ronald D. Croatti President and Chief Executive Officer Unifirst Corporation 68 Jonspin Road Wilmington, MA 01887 Facsimile: (978) 657-5663 Re: Unifirst Corporation Form 10-K for Fiscal Year Ended August 30, 2008 Filed November 13, 2008 File No. 000-08504 Dear Mr. Croatti:

We have reviewed your response letter dated April 3, 2009 and have the following comments. Please address the following comment in future filings. If you disagree, we will consider your explanation as to why our comment is inapplicable or a future revision is unnecessary. Please be as detailed as necessary in your explanation. We welcome any questions you may have about our comments or on a ny other aspect of our review. Feel free to call us at the tele phone numbers listed at th e end of th is letter.

Definitive Proxy Statement Incorporated by Reference Into Part III

Compensation Discussion and Analysis

1. We have reviewed your response to comm ent four in our letter dated March 5, 2009 and believe that you should disclose ma terial earnings per share and revenue targets in connection with annual cash in centive bonuses in future filings. Please disclose these targets in future filings to the extent they become material elements of your executive compensati on policies or decisions.

* * * * Please respond to these comments through correspondence ov er EDGAR within 10 business days or tell us when you will provid e us with a response. Please furnish a letter that keys your respons es to our comments and provide s any requested information. Detailed letters greatly faci litate our review. Please understand that we may have additional comments after reviewin g your responses to our comments.

Mr. Ronald D. Croatti Unifirst Corporation April 13, 2009 Page 2

Please contact John Harrington, Staff Attorn ey, at (202) 551-3576, or me, at (202) 551-3810, with any other questions. S i n c e r e l y ,

/ s / L a r r y S p i r g e l A s s i s t a n t D i r e c t o r

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3720         April 13, 2009  Ronald D. Croatti President and Chief Executive Officer Unifirst Corporation 68 Jonspin Road Wilmington, MA 01887 Facsimile: (978) 657-5663
 Re: Unifirst Corporation
  Form 10-K for Fiscal Year Ended August 30, 2008
  Filed November 13, 2008   File No. 000-08504
Dear Mr. Croatti:

We have reviewed your response letter dated April 3, 2009 and have the
following comments.  Please address the following comment in future filings.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a future revision is unnecessary.  Please be as detailed as necessary in your explanation.
We welcome any questions you may have about our comments or on a ny other aspect of
our review.  Feel free to call us at the tele phone numbers listed at th e end of th is letter.

Definitive Proxy Statement Incorporated by Reference Into Part III

Compensation Discussion and Analysis

1. We have reviewed your response to comm ent four in our letter dated March 5,
2009 and believe that you should disclose ma terial earnings per share and revenue
targets in connection with annual cash in centive bonuses in future filings.  Please
disclose these targets in future filings to the extent they become material elements
of your executive compensati on policies or decisions.

*    *    *    *
 Please respond to these comments through correspondence ov er EDGAR within
10 business days or tell us when you will provid e us with a response.  Please furnish a
letter that keys your respons es to our comments and provide s any requested information.
Detailed letters greatly faci litate our review.  Please understand that we may have
additional comments after reviewin g your responses to our comments.

Mr. Ronald D. Croatti
Unifirst Corporation
April 13, 2009
Page 2

Please contact John Harrington, Staff Attorn ey, at (202) 551-3576, or me, at (202)
551-3810, with any other questions.         S i n c e r e l y ,

         / s /  L a r r y  S p i r g e l          A s s i s t a n t  D i r e c t o r