SEC Comment Letter for SCANSOURCE, INC. (SCSC) (CIK 0000918965) (SCSC) — Aug 3, 2009
SCANSOURCE, INC. (SCSC) (CIK 0000918965)
Date: Aug. 3, 2009 · CIK: 0000918965 · Accession: 0000000000-09-041650
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-26926
Referenced dates: May 18, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 Mail Stop 4561 Via U.S. Mail and Facsimile (864) 286-4241 June 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 limited our review of your filing to those issues discussed with your counsel, Betty Temple, on June 3, 2009. A ll of our comments pertain to that conversation. Should you have any questions concerning our comments or any other aspect of our review, please feel free to call us at the telephone numbers listed at the end of this letter.
Annual Report on Form 10-K for fiscal year ended June 30, 2008
General
1. We refer to our conversation with y our company’s counsel on June 3, 2009 to follow-up on the comment of our comment letter dated May 18, 2009. We have been informed that two of your ten la rgest vendors – Motorola and Avaya – account for 23.9% and 20.2% of your net sales, respectively, as of March 31, 2009. Please explain why you believe that you are not substantially dependent on these vendors and why you maintain that you are not requir ed to file the distribution agreements with these ve ndors as exhibits pursuant to Item 601(b)(10)(ii)(B) of Regulation S-K.
Michael L. Baur ScanSource, Inc. June 4, 2009 Page 2 * * * * *
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
cc: Via Facsimile (864) 255-5489
Elizabeth O. Temple, Esq. Womble Carlyle
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
Mail Stop 4561
Via U.S. Mail and Facsimile (864) 286-4241
June 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 limited our review of your filing to those issues discussed with your
counsel, Betty Temple, on June 3, 2009. A ll of our comments pertain to that
conversation.
Should you have any questions concerning our comments or any other aspect of
our review, please feel free to call us at the telephone numbers listed at the end of this
letter.
Annual Report on Form 10-K for fiscal year ended June 30, 2008
General
1. We refer to our conversation with y our company’s counsel on June 3, 2009 to
follow-up on the comment of our comment letter dated May 18, 2009. We have
been informed that two of your ten la rgest vendors – Motorola and Avaya –
account for 23.9% and 20.2% of your net sales, respectively, as of March 31,
2009. Please explain why you believe that you are not substantially dependent on
these vendors and why you maintain that you are not requir ed to file the
distribution agreements with these ve ndors as exhibits pursuant to Item
601(b)(10)(ii)(B) of Regulation S-K.
Michael L. Baur
ScanSource, Inc. June 4, 2009 Page 2
* * * * *
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
cc: Via Facsimile (864) 255-5489
Elizabeth O. Temple, Esq. Womble Carlyle