SEC Comment Letter for SCANSOURCE, INC. (SCSC) (CIK 0000918965) (SCSC) — May 29, 2009
SCANSOURCE, INC. (SCSC) (CIK 0000918965)
Date: May 29, 2009 · CIK: 0000918965 · Accession: 0000000000-09-028748
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-26926
Referenced dates: May 4, 2009, May 8, 2009
Letter
Mail Stop 4561 Via U.S. Mail and Facsimile (864) 286-4241 May 18, 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 May 8, 2009 in connection with the above-referenced filing and have the follo wing 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 May 4, 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 concerning your 10 largest vendors. We specifically note your statem ent that you decided not to file your distribution agreements with your vendors pursuant to Item 601( b)(10)(ii)(B) of Regulation S-K based on your determination that these agreements are made in the ordinary course of business and th at your business is not substantially
Michael L. Baur ScanSource, Inc. May 18, 2009 Page 2 dependent on any of these distribution agreements. As previously requested, please tell us in your response whether any of your vendors constitute 10% or more of your net sales. We remind you that to the extent that you need to file any vendor agreement pursuant to Item 601(b )(10) of Regulation S-K, you may seek confidential treatment of specific pric ing 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 18, 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 May 8, 2009 in connection with the
above-referenced filing and have the follo wing 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 May 4, 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 concerning your 10 largest
vendors. We specifically note your statem ent that you decided not to file your
distribution agreements with your vendors pursuant to Item 601( b)(10)(ii)(B) of
Regulation S-K based on your determination that these agreements are made in
the ordinary course of business and th at your business is not substantially
Michael L. Baur
ScanSource, Inc. May 18, 2009 Page 2
dependent on any of these distribution agreements. As previously requested,
please tell us in your response whether any of your vendors constitute 10% or more of your net sales. We remind you that to the extent that you need to file any vendor agreement pursuant to Item 601(b )(10) of Regulation S-K, you may seek
confidential treatment of specific pric ing 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