SEC Comment Letter for Fossil Group, Inc. (FOSL) (CIK 0000883569) (FOSL) — May 17, 2018
Fossil Group, Inc. (FOSL) (CIK 0000883569)
Date: May 17, 2018 · CIK: 0000883569 · Accession: 0000000000-18-015360
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 May 17, 2018 Mr. Jeffrey N. Boyer Executive Vice President, Chief Financial Officer and Treasurer Fossil Group, Inc. 901 S. Central Expressway Richardson, TX 75080
Re: Fossil Group, Inc. Form 10-K for the Fiscal Year Ended December 30, 2017 Response Dated May 11, 2018 File No. 0-19848
Dear Mr. Boyer :
We have reviewed your May 11, 2018 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respon d. 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 commen ts are to comments in our April 23, 2018 letter .
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
1. We have reviewed your response to comment 1. In your response, you state that the information material to an investor regarding your Michael Kors and Armani licenses is that a specific minimum sales threshold exists and there is potential for early termination. Given the significance of this information, please discl ose this with in an appropriate place of your MD&A. In doing so, please disclose t hat your Michael Kors and Armani licenses may be terminated at the end of 2019 if you fail to meet specific minimum sales thresholds for 2018.
Mr. Jeffrey N. Boyer Fossil Group, Inc. May 17, 2018 Page 2
You may contact Yong Kim, St aff Accountant, at (202) 551 -3323, Andrew Blume, Staff Accountant, at (202) 551 -3254 or me at (202) 551 -3737 with any questions.
Sincerely,
/s/ Jennifer Thompson
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Mail Stop 3561 May 17, 2018 Mr. Jeffrey N. Boyer Executive Vice President, Chief Financial Officer and Treasurer Fossil Group, Inc. 901 S. Central Expressway Richardson, TX 75080 Re: Fossil Group, Inc. Form 10-K for the Fiscal Year Ended December 30, 2017 Response Dated May 11, 2018 File No. 0-19848 Dear Mr. Boyer : We have reviewed your May 11, 2018 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respon d. 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 commen ts are to comments in our April 23, 2018 letter . Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 35 1. We have reviewed your response to comment 1. In your response, you state that the information material to an investor regarding your Michael Kors and Armani licenses is that a specific minimum sales threshold exists and there is potential for early termination. Given the significance of this information, please discl ose this with in an appropriate place of your MD&A. In doing so, please disclose t hat your Michael Kors and Armani licenses may be terminated at the end of 2019 if you fail to meet specific minimum sales thresholds for 2018. Mr. Jeffrey N. Boyer Fossil Group, Inc. May 17, 2018 Page 2 You may contact Yong Kim, St aff Accountant, at (202) 551 -3323, Andrew Blume, Staff Accountant, at (202) 551 -3254 or me at (202) 551 -3737 with any questions. Sincerely, /s/ Jennifer Thompson Jennifer Thompson Accounting Branch Chief Office of Consumer Products