SEC Comment Letter for HELEN OF TROY (HELE) — Jun 11, 2020
HELEN OF TROY LTD
Date: June 11, 2020 · CIK: 0000916789 · Accession: 0000000000-20-005215
AI Filing Summary & Sentiment
File numbers found in text: 001-14669
Letter
United States securities and exchange commission logo June 11, 2020 Brian Grass Chief Financial Officer HELEN OF TROY LTD 1 Helen of Troy Plaza El Paso, Texas 79912 Re:HELEN OF TROY LTD Form 10-K for the fiscal year ended February 29, 2020 Filed April 29, 2020 File No. 001-14669 Dear Mr. Grass: We have reviewed your filing 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 our 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 our comment, we may have additional comments. Form 10-K for the fiscal year ended February 29, 2020 Notes to Consolidated Financial Statements Note 3 - Revenue Recognition, page 76 1.Please revise to clarify whether each of your non-customized consumer products represent a promised good that is a distinct performance obligation. Additionally, we note that you recognize revenue from contracts with customers at a single point in time. In this regard, please specify when you typically satisfy your performance obligations and your customer obtains control (e.g. upon shipment, upon delivery, etc.). Please also include the significant payment terms such as when payment is typically due. Refer to ASC 606-10-50-12. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameBrian Grass Comapany NameHELEN OF TROY LTD June 11, 2020 Page 2 FirstName LastName Brian Grass HELEN OF TROY LTD June 11, 2020 Page 2 You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or Jean Yu, Assistant Chief Accountant, at (202) 551-3305 if you have any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
June 11, 2020
Brian Grass
Chief Financial Officer
HELEN OF TROY LTD
1 Helen of Troy Plaza
El Paso, Texas 79912
Re:HELEN OF TROY LTD
Form 10-K for the fiscal year ended February 29, 2020
Filed April 29, 2020
File No. 001-14669
Dear Mr. Grass:
We have reviewed your filing 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 our 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 our comment, we may have additional comments.
Form 10-K for the fiscal year ended February 29, 2020
Notes to Consolidated Financial Statements
Note 3 - Revenue Recognition, page 76
1.Please revise to clarify whether each of your non-customized consumer
products represent a promised good that is a distinct performance obligation.
Additionally, we note that you recognize revenue from contracts with customers at a
single point in time. In this regard, please specify when you typically satisfy your
performance obligations and your customer obtains control (e.g. upon shipment, upon
delivery, etc.). Please also include the significant payment terms such as when payment is
typically due. Refer to ASC 606-10-50-12.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameBrian Grass
Comapany NameHELEN OF TROY LTD
June 11, 2020 Page 2
FirstName LastName
Brian Grass
HELEN OF TROY LTD
June 11, 2020
Page 2
You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or Jean Yu,
Assistant Chief Accountant, at (202) 551-3305 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing