SEC Company Response from HELEN OF TROY (HELE) — Oct 30, 2015
HELEN OF TROY LTD
Date: Oct. 30, 2015 · CIK: 0000916789 · Accession: 0001104659-15-074517
AI Filing Summary & Sentiment
Letter
United States Via Edgar- Correspondence Only United States Securities and Exchange Commission 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,
On behalf of our client, Helen of Troy Limited (the “Company”), we submit this letter in response to the verbal comment by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received during a telephone conversation on October 22, 2015.
In response to the Staff’s comment, the Company will provide additional disclosure in the Company’s future annual reports as to its ability to satisfy the thresholds applicable to maintaining its eligibility to receive the Macau tax holiday that has been granted to the Company’s Macau subsidiary.
* * *
In response to the Staff’s request, the Company has acknowledged certain matters on Exhibit A attached hereto. Should you have any additional questions or comments, please do not hesitate to contact me at (214) 978-3042 or Vince Carson of the Company at (915) 225-8033.
Paris
Prague
Riyadh*
Rome
St. Petersburg
Stockholm
Vienna
Warsaw
Zurich
Latin America
Bogota
Brasilia**
Buenos Aires
Caracas
Guadalajara
Juarez
Lima
Mexico City
Monterrey
Porto Alegre**
Rio de Janeiro**
Santiago
Sao Paulo**
Tijuana
Valencia
North America
Chicago
Dallas
Houston
Miami
New York
Palo Alto
San Francisco
Toronto
Washington, DC
* Associated Firm
** In cooperation with Trench, Rossi e Watanabe Advogados
Regards,
/s/ W. Crews Lott
W. Crews Lott
Partner
214-978-3042
Crews.Lott@bakermckenzie.com
Encl.
Cc: Terry French Christy Adams
Helen of Troy Limited
Brian L. Grass
Vincent D. Carson
Baker & McKenzie LLP is a member of Baker & McKenzie International, a Swiss Verein.
Exhibit A
October 30, 2015
Via Edgar- Correspondence Only
United States Securities and Exchange Commission
Division of Corporation Finance 100 F Street, N.E. Mail Stop 3720 Washington, DC 20549-7010
In response to the request of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), Helen of Troy Limited (the “Company”) acknowledges to the Staff 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.
Regards,
/s/ Vincent D. Carson
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CORRESP 1 filename1.htm Baker & McKenzie LLP 2300 Trammell Crow Center 2001 Ross Avenue Dallas, TX 75201 United States Tel: +1 214 978 3000 Fax: +1 214 978 3099 www.bakermckenzie.com Asia Pacific Bangkok Beijing Brisbane Hanoi Ho Chi Minh City Hong Kong Jakarta* Kuala Lumpur* Manila* Melbourne Seoul Shanghai Singapore Sydney Taipei Tokyo Yangon Europe, Middle East & Africa Abu Dhabi Almaty Amsterdam Antwerp Bahrain Baku Barcelona Berlin Brussels Budapest Cairo Casablanca Doha Dubai Dusseldorf Frankfurt/Main Geneva Istanbul Jeddah* Johannesburg Kyiv London Luxembourg Madrid Munich October 30, 2015 Via Edgar- Correspondence Only United States Securities and Exchange Commission 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, On behalf of our client, Helen of Troy Limited (the “Company”), we submit this letter in response to the verbal comment by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received during a telephone conversation on October 22, 2015. In response to the Staff’s comment, the Company will provide additional disclosure in the Company’s future annual reports as to its ability to satisfy the thresholds applicable to maintaining its eligibility to receive the Macau tax holiday that has been granted to the Company’s Macau subsidiary. * * * In response to the Staff’s request, the Company has acknowledged certain matters on Exhibit A attached hereto. Should you have any additional questions or comments, please do not hesitate to contact me at (214) 978-3042 or Vince Carson of the Company at (915) 225-8033. Paris Prague Riyadh* Rome St. Petersburg Stockholm Vienna Warsaw Zurich Latin America Bogota Brasilia** Buenos Aires Caracas Guadalajara Juarez Lima Mexico City Monterrey Porto Alegre** Rio de Janeiro** Santiago Sao Paulo** Tijuana Valencia North America Chicago Dallas Houston Miami New York Palo Alto San Francisco Toronto Washington, DC * Associated Firm ** In cooperation with Trench, Rossi e Watanabe Advogados Regards, /s/ W. Crews Lott W. Crews Lott Partner 214-978-3042 Crews.Lott@bakermckenzie.com Encl. Cc: Terry French Christy Adams Helen of Troy Limited Brian L. Grass Vincent D. Carson Baker & McKenzie LLP is a member of Baker & McKenzie International, a Swiss Verein. Exhibit A October 30, 2015 Via Edgar- Correspondence Only United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Mail Stop 3720 Washington, DC 20549-7010 In response to the request of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), Helen of Troy Limited (the “Company”) acknowledges to the Staff 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. Regards, /s/ Vincent D. Carson Vincent D. Carson Chief Legal Officer and Secretary