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SEC Comment Letter for SCANSOURCE, INC. (SCSC) (CIK 0000918965) (SCSC) — May 4, 2009

SCANSOURCE, INC. (SCSC) (CIK 0000918965)
Date: May 4, 2009 · CIK: 0000918965 · Accession: 0000000000-09-023561

AI Filing Summary & Sentiment

File numbers found in text: 000-26926

Referenced dates: April 2, 2009, April 21, 2009

Date
May 4, 2009
Author
Not clearly detected
Form
UPLOAD
Company
SCANSOURCE, INC. (SCSC) (CIK 0000918965)

Letter

Mail Stop 4561 Via U.S. Mail and Facsimile (864) 286-4241 May 4, 2009 Michael L. Baur Chief Executive Officer ScanSource, Inc. 6 Logue Court Greenville, South Carolina 29615

Re: ScanSource, Inc. Form 10-K for Fiscal Year Ended June 30, 2008 Filed August 28, 2008 File No. 000-26926

Dear Mr. Baur:

We have reviewed your response letter dated April 21, 2009 in connection with the above-referenced filing and have the followi ng comment. If indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. In our comment, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this inform ation, we may raise additional comments. Unless otherwise noted, where prior comments ar e referred to they refer to our letter dated April 2, 2009 Annual Report on Form 10-K for fiscal year ended June 30, 2008

Part I

Item 1. Business, page 1

General

1. We note your response to comment 1 of our letter regarding the consideration you gave to providing the name s of, and a description of the material terms of your relationships with, your ten largest vendors and clarifying whether you are substantially dependent on any of these relationships. We specifically note your statement that as a distribution compa ny, your relationships with your vendors,

Michael L. Baur ScanSource, Inc. May 4, 2009 Page 2 including the agreements with such vendors to constitute “significant confidential information.” We have considered your re sponse and we continue to believe that since your success is “highly dependent” on these vendor relationships (i.e., products for your ten largest vendors acc ounted for approximately 85% of net sales for fiscal 2008), information regarding these relationships is material to an investor. As such, we reiterate our position that you should provide the names of, and a description of any mate rial vendor relationships that you might have. Your stated concern that the names of vendors may become outdated over time can be addressed by identifying the vendors as of a certain point in time, such as December 31, 2008. With respect to your statement that you are “currently not dependent on any one of these relationshi ps,” please help us to understand your position. For example, does each vendor constitute less than 10% of net sales? As you know, to the extent that you need to file any vendor agreement pursuant to Item 601(b)(10), you may seek confidential treatment of specific pricing or other confidential information pursuant to Rule 24b-2 of the Exchange Act.

* * * * *

Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please submit all correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your filing(s), you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter that keys your response to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comm ents after reviewing any amendment and your response to our comment. Please contact Ryan Houseal, Attorney-Advisor at (202) 551-3105 or, in his absence, me at (202) 551-3735 with any questions. Sincerely,

Barbara C. Jacobs Assistant Director

Show Raw Text
Mail Stop 4561 Via U.S. Mail and Facsimile (864) 286-4241

         May 4, 2009  Michael L. Baur Chief Executive Officer ScanSource, Inc. 6 Logue Court Greenville, South Carolina 29615

Re: ScanSource, Inc.
 Form 10-K for Fiscal Year Ended June 30, 2008  Filed August 28, 2008  File No. 000-26926

Dear Mr. Baur:

We have reviewed your response letter  dated April 21, 2009 in connection with
the above-referenced filing and have the followi ng comment.  If indicated, we think you
should revise your document in response to this comment.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detaile d as necessary in your explan ation.  In our comment, we
may ask you to provide us with supplemental information so we may better understand your disclosure.  After reviewing this inform ation, we may raise additional comments.
Unless otherwise noted, where prior comments ar e referred to they refer to our letter
dated April 2, 2009
Annual Report on Form 10-K for fiscal year ended June 30, 2008

Part I

Item 1. Business, page 1

General

1. We note your response to comment 1 of our  letter regarding the consideration you
gave to providing the name s of, and a description of the material terms of your
relationships with, your ten largest vendors and clarifying whether you are
substantially dependent on any of these relationships.  We specifically note your statement that as a distribution compa ny, your relationships with your vendors,

Michael L. Baur
ScanSource, Inc. May 4, 2009 Page 2
including the agreements with such vendors to constitute “significant confidential information.” We have considered your re sponse and we continue to believe that
since your success is “highly dependent”  on these vendor relationships (i.e.,
products for your ten largest vendors acc ounted for approximately 85% of net
sales for fiscal 2008), information regarding these relationships is material to an
investor. As such, we reiterate our position that you should provide the names of, and a description of any mate rial vendor relationships that you might have. Your
stated concern that the names of vendors may become outdated over time can be addressed by identifying the vendors as of a certain point in time, such as December 31, 2008. With respect to your statement that you are “currently not
dependent on any one of these relationshi ps,” please help us to understand your
position. For example, does each vendor constitute less than 10% of net sales? As you know, to the extent that you need to file any vendor agreement pursuant to
Item 601(b)(10), you may seek confidential treatment of specific pricing or other confidential information pursuant to Rule 24b-2 of the Exchange Act.

* * * * *

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please submit all correspondence and supplemental materials
on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comment and provides any
requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comm ents after reviewing any amendment and
your response to our comment.   Please contact Ryan Houseal, Attorney-Advisor at (202) 551-3105 or, in his absence, me at (202) 551-3735 with any questions.
Sincerely,

Barbara C. Jacobs Assistant Director