SEC Company Response from HELEN OF TROY (HELE) — Oct 13, 2015
HELEN OF TROY LTD
Date: Oct. 13, 2015 · CIK: 0000916789 · Accession: 0001104659-15-070391
AI Filing Summary & Sentiment
Referenced dates: September 10, 2015
Letter
United States Securities and Exchange Commission Division of Corporation Finance Attention: Mr. Larry Spirgel Re: Helen of Troy Limited Form 10-K for Fiscal Year Ended February 28, 2015 Filed April 29, 2015 File No. 1-14669
Dear Mr. Spirgel:
Helen of Troy Limited (the “Company”) submits this letter to supplement the letter sent on its behalf by Baker & McKenzie LLP dated October 8, 2015 in response to the written comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated September 10, 2015 (the “Comment Letter”) relating to the above-referenced Form 10-K.
In response to your request in the Comment Letter, the Company acknowledges that:
· the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
· Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and
· the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Should you have any additional questions or comments, please do not hesitate to contact Crews Lott at (214) 978-3042 or me at (915) 225-8033.
Regards,
/s/ Vincent D. Carson
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CORRESP 1 filename1.htm HELEN OF TROY LIMITED Clarendon House 2 Church Street Hamilton, Bermuda October 13, 2015 United States Securities and Exchange Commission By EDGAR Division of Corporation Finance 100 F Street, N.E. Mail Stop 3720 Washington, DC 20549-7010 Attention: Mr. Larry Spirgel Re: Helen of Troy Limited Form 10-K for Fiscal Year Ended February 28, 2015 Filed April 29, 2015 File No. 1-14669 Dear Mr. Spirgel: Helen of Troy Limited (the “Company”) submits this letter to supplement the letter sent on its behalf by Baker & McKenzie LLP dated October 8, 2015 in response to the written comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated September 10, 2015 (the “Comment Letter”) relating to the above-referenced Form 10-K. In response to your request in the Comment Letter, the Company acknowledges that: · the Company is responsible for the adequacy and accuracy of the disclosure in the filing; · Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and · the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Should you have any additional questions or comments, please do not hesitate to contact Crews Lott at (214) 978-3042 or me at (915) 225-8033. Regards, /s/ Vincent D. Carson Vincent D. Carson Chief Legal Officer and Secretary 1