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
AI Filing Summary & Sentiment
File numbers found in text: 000-08504
Referenced dates: April 3, 2009, March 5, 2009
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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