SEC Comment Letter for CARLISLE COMPANIES (CSL) — Jan 31, 2012
CARLISLE COMPANIES INC
Date: Jan. 31, 2012 · CIK: 0000790051 · Accession: 0000000000-12-005386
AI Filing Summary & Sentiment
Referenced dates: December 27, 2011, December 27, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE January 31, 2012 Via Facsimile Mr. Steven J. Ford Chief Financial Officer Carlisle Companies Incorporated 13925 Ballantyne Corporate Place, Suite 400 Charlotte, North Carolina 28277 RE: Carlisle Companies Incorporated Form 10-K for the Year Ended December 31, 2010 Filed February 16, 2011 Form 10-Q for the Period Ended September 30, 2011 Filed October 25, 2011 Response dated January 11, 2012 File No. 1-9278
Dear Mr. Ford:
We have reviewed your response letter da ted January 11, 2012 and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2010
Financial Statements
Notes to the Financial Statements
Note 9 – Acquisitions, page 56 1. We note your response to comment six from our letter dated December 27, 2011. Please provide more transparent disclo sures regarding the periods used to amortize your customer relationships in a similar manner to your res ponse. You may summarize this information by
Mr. Steven J. Ford Carlisle Companies Incorporated January 31, 2012 Page 2 aggregating useful lives by meaningful ra nges of useful lives. Please show us supplementally what your revised disclosures will look like. Note 17 - Commitments and Contingencies, page 76
Litigation, page 77
2. We note your response to comments seven and eight from our letter dated December 27, 2011. Your revised disclosure st ates that the ultimate outcome of other legal actions may have more than an inconsequential impact on your results of operations for a particular period, which indicates that the ultimate outcome may be material. It is not clear how this corresponds to your response to comment eight in which you indicate that the estimate of any loss exceeding amounts accrued is immaterial. Please advise or revise your disclosures as necessary. Please show us supplementally what your revised disclosures will look like.
You may contact Ernest Greene, Staff Acc ountant at (202) 551- 3733 or Nudrat Salik, Staff Accountant at (202) 551-3692 if you ha ve questions regarding these comments. S i n c e r e l y ,
/s/ Rufus Decker
R u f u s D e c k e r A c c o u n t i n g B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
January 31, 2012
Via Facsimile
Mr. Steven J. Ford
Chief Financial Officer Carlisle Companies Incorporated 13925 Ballantyne Corporate Place, Suite 400 Charlotte, North Carolina 28277
RE: Carlisle Companies Incorporated
Form 10-K for the Year Ended December 31, 2010
Filed February 16, 2011 Form 10-Q for the Period Ended September 30, 2011 Filed October 25, 2011 Response dated January 11, 2012 File No. 1-9278
Dear Mr. Ford:
We have reviewed your response letter da ted January 11, 2012 and have the following
comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments. Form 10-K for the Year Ended December 31, 2010
Financial Statements
Notes to the Financial Statements
Note 9 – Acquisitions, page 56
1. We note your response to comment six from our letter dated December 27, 2011. Please
provide more transparent disclo sures regarding the periods used to amortize your customer
relationships in a similar manner to your res ponse. You may summarize this information by
Mr. Steven J. Ford
Carlisle Companies Incorporated January 31, 2012 Page 2
aggregating useful lives by meaningful ra nges of useful lives. Please show us
supplementally what your revised disclosures will look like.
Note 17 - Commitments and Contingencies, page 76
Litigation, page 77
2. We note your response to comments seven and eight from our letter dated December 27,
2011. Your revised disclosure st ates that the ultimate outcome of other legal actions may
have more than an inconsequential impact on your results of operations for a particular
period, which indicates that the ultimate outcome may be material. It is not clear how this
corresponds to your response to comment eight in which you indicate that the estimate of any
loss exceeding amounts accrued is immaterial. Please advise or revise your disclosures as
necessary. Please show us supplementally what your revised disclosures will look like.
You may contact Ernest Greene, Staff Acc ountant at (202) 551- 3733 or Nudrat Salik,
Staff Accountant at (202) 551-3692 if you ha ve questions regarding these comments.
S i n c e r e l y ,
/s/ Rufus Decker
R u f u s D e c k e r
A c c o u n t i n g B r a n c h C h i e f