SEC Comment Letter for SIGNET JEWELERS LTD (SIG) (CIK 0000832988) (SIG) — Nov 7, 2019
SIGNET JEWELERS LTD (SIG) (CIK 0000832988)
Date: Nov. 7, 2019 · CIK: 0000832988 · Accession: 0000000000-19-015294
AI Filing Summary & Sentiment
File numbers found in text: 001-32349
Letter
October 10, 2019 Joan Hilson Chief Financial Officer Signet Jewelers Limited Clarendon House 2 Church Street Hamilton HM11 Bermuda Re:Signet Jewelers Limited Form 10-K for the Fiscal year Ended February 2, 2019 Filed April 3, 2019 Form 10-Q for the Quarterly Period Ended August 3, 2019 Filed August 3, 2019 Correspondence filed September 25, 2019 File No. 001-32349 Dear Ms. Hilson: We have reviewed your September 25, 2019 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 12, 2019 letter. Form 10-Q for the Quarterly Period Ended August 3, 2019 Notes to the Consolidated Financial Statements 14. Goodwill and intangibles, page 20 1.We reviewed your response to comment 4. With respect to the impact of the error on the current year we note qualitatively you do not expect it to be material to your profitability or trends in 2020. Please explain why the error is quantitatively immaterial to the current year in light of your guidance.
FirstName LastNameJoan Hilson Comapany NameSignet Jewelers Limited October 10, 2019 Page 2 FirstName LastName Joan Hilson Signet Jewelers Limited October 10, 2019 Page 2 You may contact Scott Stringer at 202-551-3342, or me, Bill Thompson, at 202-551-3344 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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October 10, 2019
Joan Hilson
Chief Financial Officer
Signet Jewelers Limited
Clarendon House
2 Church Street
Hamilton HM11
Bermuda
Re:Signet Jewelers Limited
Form 10-K for the Fiscal year Ended February 2, 2019
Filed April 3, 2019
Form 10-Q for the Quarterly Period Ended August 3, 2019
Filed August 3, 2019
Correspondence filed September 25, 2019
File No. 001-32349
Dear Ms. Hilson:
We have reviewed your September 25, 2019 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
September 12, 2019 letter.
Form 10-Q for the Quarterly Period Ended August 3, 2019
Notes to the Consolidated Financial Statements
14. Goodwill and intangibles, page 20
1.We reviewed your response to comment 4. With respect to the impact of the error on the
current year we note qualitatively you do not expect it to be material to your profitability
or trends in 2020. Please explain why the error is quantitatively immaterial to the current
year in light of your guidance.
FirstName LastNameJoan Hilson
Comapany NameSignet Jewelers Limited
October 10, 2019 Page 2
FirstName LastName
Joan Hilson
Signet Jewelers Limited
October 10, 2019
Page 2
You may contact Scott Stringer at 202-551-3342, or me, Bill Thompson, at 202-551-3344
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services