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
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File numbers found in text: 001-09764
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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