SEC Comment Letter for Fossil Group, Inc. (FOSL) (CIK 0000883569) (FOSL) — Sep 12, 2012
Fossil Group, Inc. (FOSL) (CIK 0000883569)
Date: Sept. 12, 2012 · CIK: 0000883569 · Accession: 0000000000-12-049877
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-19848
Referenced dates: August 6, 2012
Letter
September 12 , 2012 Via E -Mail Kosta N. Kartsotis Chief Executive Officer Fossil, Inc. 901 S. Central Expressway Richardson, TX 75080
Re: Fossil, Inc. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 29, 2012 Response dated August 29, 2012 File No. 000-19848
Dear Mr. Kartsotis:
We have reviewed your response and have the following additional comment s. In our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, 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 circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the Fiscal Year Ended December 31, 2011
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 41
Liquidity and Capital Resources, pa ge 53
1. We note your response to comment 7 in our letter dated August 6, 2012. Please ensure that your expanded disclosure also addresses the source of funds needed to fulfill such commitments.
Kosta N. Kartsotis Fossil, Inc. September 12 , 2012 Page 2
Item 8. Consolidated Financial Statements and Supplemen tary Data, page 59
Consolidated Statements of Cash Flow, page 63
2. We note your response to comment 8 in our letter dated August 6, 2012 and your disclosure of the increase in the allowance for doubtful accounts in your Consolidated Statements of Cash Flows. Please revise in future filings to disclose on the face of your Consolidated Statements of Income and Comprehensive Income your provision for doubtful accounts as required by Rule 5 -03.5 of Regulation S -X. Please note that the total amount charged to costs and expenses relating to your doubtful accounts receivables reflected on the face of your statements of income should correspond to that amount of additions charged to operations shown in your Schedule II.
You may contact Donna Di Silvio, Staff Accountant, at (202) 551 -3202 or me at (202) 551-3377 if you have questions regarding comments on the financial statements and related matters. Please contact Mara Ransom, Assistant Director, at (202) 551 -3264 with any other questions.
Sincerely,
/s/ Andrew D. Mew
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September 12 , 2012 Via E -Mail Kosta N. Kartsotis Chief Executive Officer Fossil, Inc. 901 S. Central Expressway Richardson, TX 75080 Re: Fossil, Inc. Form 10-K for the Fiscal Year Ended December 31, 2011 Filed February 29, 2012 Response dated August 29, 2012 File No. 000-19848 Dear Mr. Kartsotis: We have reviewed your response and have the following additional comment s. In our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, 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 circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10 -K for the Fiscal Year Ended December 31, 2011 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 41 Liquidity and Capital Resources, pa ge 53 1. We note your response to comment 7 in our letter dated August 6, 2012. Please ensure that your expanded disclosure also addresses the source of funds needed to fulfill such commitments. Kosta N. Kartsotis Fossil, Inc. September 12 , 2012 Page 2 Item 8. Consolidated Financial Statements and Supplemen tary Data, page 59 Consolidated Statements of Cash Flow, page 63 2. We note your response to comment 8 in our letter dated August 6, 2012 and your disclosure of the increase in the allowance for doubtful accounts in your Consolidated Statements of Cash Flows. Please revise in future filings to disclose on the face of your Consolidated Statements of Income and Comprehensive Income your provision for doubtful accounts as required by Rule 5 -03.5 of Regulation S -X. Please note that the total amount charged to costs and expenses relating to your doubtful accounts receivables reflected on the face of your statements of income should correspond to that amount of additions charged to operations shown in your Schedule II. You may contact Donna Di Silvio, Staff Accountant, at (202) 551 -3202 or me at (202) 551-3377 if you have questions regarding comments on the financial statements and related matters. Please contact Mara Ransom, Assistant Director, at (202) 551 -3264 with any other questions. Sincerely, /s/ Andrew D. Mew Andrew D. Mew Accounting Branch Chief cc: Mike L. Kovar