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SEC Company Response from HARMAN INTERNATIONAL INDUSTRIES — Mar 2, 2005

HARMAN INTERNATIONAL INDUSTRIES INC /DE/ (CIK 0000800459)
Date: March 2, 2005 · CIK: 0000800459 · Accession: 0000950134-05-004117

AI Filing Summary & Sentiment

File numbers found in text: 001-09764

Date
March 2, 2005
Author
/s/ Frank Meredith
Form
CORRESP
Company
HARMAN INTERNATIONAL INDUSTRIES INC /DE/ (CIK 0000800459)

Letter

Harman International Industries, Incorporated

8500 Balboa Blvd.

P.O. Box 2200

Northridge, CA 91329

Tel (818) 893-8411

March 2, 2005

BY EDGAR

United States Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attn: Larry Spirgel, Assistant Director

Re: Harman International Industries, Incorporated

Form 10-K for fiscal year ended June 30, 2004

File Date: September 8, 2004

File No. 001-09764

Ladies and Gentlemen:

We received your letter, dated February 18, 2005 and understand that our outside counsel, James O’Bannon at Jones Day, discussed your letter with Robert Littlepage. In response to the Staff’s letter, we will agree to report Consumer Home and Consumer Automotive (currently aggregated and reported as the Consumer Systems Group) as separate reporting segments in accordance with FAS 131 in our Exchange Act filings with the Commission.

As discussed with Mr. Littlepage, Harman would prefer not to amend its Form 10-K for the fiscal year ended June 30, 2004 but would propose the following. Harman would first report information with respect to the Consumer Home and Consumer Automotive segments in its Form 10-Q for the three and nine months ended March 31, 2005. In addition, in its March 31, 2005 Report on Form 10-Q, Harman would supplementally provide information regarding its Consumer Home and Consumer Automotive segments for each of its fiscal years ended June 30, 2002, 2003 and 2004.

Based on our preliminary analysis, I estimate that it will take approximately eight weeks for us to review our historical financial information in order to have segment information for Consumer Home and Consumer Automotive prepared internally. This period of time is required for two reasons. First, as the Staff is aware, we have never reported Consumer Home and Consumer Automotive as separate segments. We intend to review the asset allocations, overhead allocations for shared facilities and management and the allocation of intangibles

United States Securities and Exchange Commission

March 2, 2005

Page 2

(including trademarks and patents) and submit for review by KPMG before publicly reporting this segment information.

As the Staff is also aware, we are in the process of documenting our processes and testing internal controls as part of management’s assessment of internal controls over financial reporting for the fiscal year ended June 30, 2005. We are devoting significant internal resources to this process in order to be in a position to allow KPMG to complete its fieldwork on the audit of internal controls.

We appreciate your consideration of our proposal in response to the Staff’s letter requesting a change in our segment reporting. If you have any further questions, please do not hesitate to contact me at (818) 895-5710 or via fax at (818) 894-6757 or James O’Bannon of Jones Day at (214) 969-3766 (fax: (214) 969-5100).

Very truly yours,
/s/ Frank Meredith

Show Raw Text
CORRESP
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corresp

Harman International Industries, Incorporated

8500 Balboa Blvd.

P.O. Box 2200

Northridge, CA 91329

Tel (818) 893-8411

March 2, 2005

BY EDGAR

United States Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

Attn: Larry Spirgel, Assistant Director

    Re:
    Harman International Industries, Incorporated

Form 10-K for fiscal year ended June 30, 2004

File Date: September 8, 2004

File No. 001-09764

Ladies and Gentlemen:

      We received your letter, dated February 18, 2005 and understand that our outside counsel,
James O’Bannon at Jones Day, discussed your letter with Robert Littlepage. In response to the
Staff’s letter, we will agree to report Consumer Home and Consumer Automotive (currently aggregated
and reported as the Consumer Systems Group) as separate reporting segments in accordance with FAS
131 in our Exchange Act filings with the Commission.

      As discussed with Mr. Littlepage, Harman would prefer not to amend its Form 10-K for the
fiscal year ended June 30, 2004 but would propose the following. Harman would first report
information with respect to the Consumer Home and Consumer Automotive segments in its Form 10-Q for
the three and nine months ended March 31, 2005. In addition, in its March 31, 2005 Report on Form
10-Q, Harman would supplementally provide information regarding its Consumer Home and Consumer
Automotive segments for each of its fiscal years ended June 30, 2002, 2003 and 2004.

      Based on our preliminary analysis, I estimate that it will take approximately eight weeks for
us to review our historical financial information in order to have segment information for Consumer
Home and Consumer Automotive prepared internally. This period of time is required for two reasons.
First, as the Staff is aware, we have never reported Consumer Home and Consumer Automotive as
separate segments. We intend to review the asset allocations, overhead allocations for shared
facilities and management and the allocation of intangibles

United States Securities and Exchange Commission

March 2, 2005

Page 2

(including trademarks and patents) and submit for review by KPMG before publicly reporting
this segment information.

      As the Staff is also aware, we are in the process of documenting our processes and testing
internal controls as part of management’s assessment of internal controls over financial reporting
for the fiscal year ended June 30, 2005. We are devoting significant internal resources to this
process in order to be in a position to allow KPMG to complete its fieldwork on the audit of
internal controls.

      We appreciate your consideration of our proposal in response to the Staff’s letter requesting
a change in our segment reporting. If you have any further questions, please do not hesitate to
contact me at (818) 895-5710 or via fax at (818) 894-6757 or James O’Bannon of Jones Day at (214)
969-3766 (fax: (214) 969-5100).

Very truly yours,

/s/ Frank Meredith

Frank Meredith

Executive Vice President and

Chief Financial Officer

    cc:
    Robert S. Littlepage, Accountant Branch Chief

Andrew Walker, Staff Accountant

James E. O’Bannon, Jones Day

William B. Hall, KPMG, LLP