SEC Comment Letter for UNIFIRST CORP (UNF) (CIK 0000717954) (UNF) — Mar 24, 2011
UNIFIRST CORP (UNF) (CIK 0000717954)
Date: March 24, 2011 · CIK: 0000717954 · Accession: 0000000000-11-018185
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-08504
Referenced dates: February 24, 2011
Letter
March 24, 2011 Mr. Ronald D. Croatti President and Chief Executive Officer UniFirst Corporation 68 Jonspin Road Wilmington, Massachusetts 01887 Re: UniFirst Corporation Form 10-K for the Year Ended August 28, 2010 Filed October 27, 2010 File No. 001-08504
Dear Mr. Croatti: We have reviewed your supplemental response dated March 22, 2011 and have the following comment. Please respond to this letter within ten business days and indicate that you will comply with our comment in future filings. Confirm in writing that you will do so and also explain to us how you intend to comply. If you do not believe our comment applies to your facts and circumstances or do not believe complia nce in future disclosure is appropriate, please tell us why in your response. After reviewing the information you provi de in response to our comment, we may have additional comments. Definitive Proxy Statement
Executive Compensation
Outstanding Equity Awards at Fiscal Year-End – 2010
1. We note your response to comment two from our letter dated February 24, 2011. However, because the 350,000 share restricted stock award reported in your table is no longer subject to performance-based condi tions, but instead remains subject to service-based vesting, the award should be reported under the “Number of Shares of Stock That Have Not Vested” column. See Question 122.03 of Regulation S-K’s Compliance and Disclosure Interpreta tions, available on our website at
Mr. Ronald D. Croatti UniFirst Corporation March 24, 2011 Page 2 http://www.sec.gov/divisions/corpf in/guidance/regs-kinterp.htm . Please confirm your understanding in your response.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company and its management are in possession of all facts relating to a co mpany’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
You may contact Joseph Ca scarano, 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 Jonathan Groff, Staff Attorney, at 202-551-3458 or me at 202-551-3810 with any other questions.
Sincerely,
/s/ John Harrington for
Larry Spirgel
A s s i s t a n t D i r e c t o r
Show Raw Text
March 24, 2011
Mr. Ronald D. Croatti President and Chief Executive Officer
UniFirst Corporation
68 Jonspin Road Wilmington, Massachusetts 01887
Re: UniFirst Corporation
Form 10-K for the Year Ended August 28, 2010 Filed October 27, 2010 File No. 001-08504
Dear Mr. Croatti:
We have reviewed your supplemental response dated March 22, 2011 and have the
following comment.
Please respond to this letter within ten business days and indicate that you will
comply with our comment in future filings. Confirm in writing that you will do so and also explain to us how you intend to comply. If you do not believe our comment applies to your
facts and circumstances or do not believe complia nce in future disclosure is appropriate,
please tell us why in your response.
After reviewing the information you provi de in response to our comment, we may
have additional comments. Definitive Proxy Statement
Executive Compensation
Outstanding Equity Awards at Fiscal Year-End – 2010
1. We note your response to comment two from our letter dated February 24, 2011.
However, because the 350,000 share restricted stock award reported in your table is
no longer subject to performance-based condi tions, but instead remains subject to
service-based vesting, the award should be reported under the “Number of Shares of
Stock That Have Not Vested” column. See Question 122.03 of Regulation S-K’s
Compliance and Disclosure Interpreta tions, available on our website at
Mr. Ronald D. Croatti
UniFirst Corporation March 24, 2011 Page 2
http://www.sec.gov/divisions/corpf in/guidance/regs-kinterp.htm
. Please confirm your
understanding in your response.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchan ge Act rules require. Since the company and
its management are in possession of all facts relating to a co mpany’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
You may contact Joseph Ca scarano, 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 Jonathan Groff, Staff Attorney, at 202-551-3458 or me at 202-551-3810 with any other questions.
Sincerely,
/s/ John Harrington for
Larry Spirgel
A s s i s t a n t D i r e c t o r