SEC Comment Letter for MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968) (MHK) — Nov 5, 2008
MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968)
Date: Nov. 5, 2008 · CIK: 0000851968 · Accession: 0000000000-08-055130
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13697
Referenced dates: October 1, 2008, September 24, 2008
Letter
Mail Stop 3561 November 5, 2008 Jeffrey S. Lorberbaum Chairman, President, and Chief Executive Officer Mohawk Industries, Inc. P.O. Box 12069 160 S. Industrial Blvd. Calhoun, GA 30701
Re: Mohawk Industries, Inc. Form 10-K for Fiscal Year Ended December 31, 2007 Filed February 29, 2008 Definitive Proxy Statement on Schedule 14A Filed April 7, 2008 File No. 001-13697
Dear Mr. Lorberbaum:
We have reviewed your response letter dated October 1, 2008 and have the following additional comment. You should comply with the comment in all future filings, as applicable. Please confirm in writin g that you will do so and also explain to us in sufficient detail how you intend to comply by providing us with your proposed revisions.
Definitive Proxy on Schedule 14A
Compensation Discussion and Analysis, page 9 1. We note your response to comment one in our letter dated September 24, 2008. Please specifically explain how disclosure of company earnings per share targets for a completed fiscal year could allow competitors to determine the company’s views on trends in raw material prices and overall cost of goods sold. Please provide similar analysis for the Unilin EBITDA targets.
Jeffrey S. Lorberbaum Mohawk Industries, Inc. November 5, 2008 Page 2 Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested information. Detailed letters gr eatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comments.
You may contact Jennifer Thompson, Accounting Bran ch Chief, at (202) 551- 3737, if you have any questions regarding the financial statements and related matters. Please contact Ronald E. Alper, Staff Attorney, at (202) 551-3329, Ellie Bavaria, Special Counsel, at (202) 551-3238, or me, at (202) 551-3720, with any other questions.
Sincerely,
H. Christopher Owings
Assistant Director
Show Raw Text
Mail Stop 3561
November 5, 2008
Jeffrey S. Lorberbaum
Chairman, President, and Chief Executive Officer
Mohawk Industries, Inc.
P.O. Box 12069
160 S. Industrial Blvd.
Calhoun, GA 30701
Re: Mohawk Industries, Inc.
Form 10-K for Fiscal Year Ended December 31, 2007
Filed February 29, 2008
Definitive Proxy Statement on Schedule 14A
Filed April 7, 2008
File No. 001-13697
Dear Mr. Lorberbaum:
We have reviewed your response letter dated October 1, 2008 and have the
following additional comment. You should comply with the comment in all future
filings, as applicable. Please confirm in writin g that you will do so and also explain to us
in sufficient detail how you intend to comply by providing us with your proposed revisions.
Definitive Proxy on Schedule 14A
Compensation Discussion and Analysis, page 9
1. We note your response to comment one in our letter dated September 24, 2008.
Please specifically explain how disclosure of company earnings per share targets
for a completed fiscal year could allow competitors to determine the company’s views on trends in raw material prices and overall cost of goods sold. Please
provide similar analysis for the Unilin EBITDA targets.
Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
November 5, 2008 Page 2
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please furnish a letter that keys your response to our
comment and provides any requested information. Detailed letters gr eatly facilitate our
review. Please understand that we may have additional comments after reviewing your
response to our comments.
You may contact Jennifer Thompson, Accounting Bran ch Chief, at (202) 551-
3737, if you have any questions regarding the financial statements and related matters.
Please contact Ronald E. Alper, Staff Attorney, at (202) 551-3329, Ellie Bavaria, Special Counsel, at (202) 551-3238, or me, at (202) 551-3720, with any other questions.
Sincerely,
H. Christopher Owings
Assistant Director
cc: R. David Patton, Esq.
Via facsimile (404) 881-7777