SEC Comment Letter for HENRY SCHEIN INC (HSIC) (CIK 0001000228) (HSIC) — Jul 22, 2011
HENRY SCHEIN INC (HSIC) (CIK 0001000228)
Date: July 22, 2011 · CIK: 0001000228 · Accession: 0000000000-11-044627
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-27078
Referenced dates: May 27, 2011
Letter
July 22, 2011 Via E-Mail Stanley M. Bergman, Chief Executive Officer Henry Schein, Inc. 135 Duryea Road Melville, NY 11747 Re: Henry Schein, Inc. Form 10-K for the Fiscal Year Ended December 25, 2010 Filed February 22, 2011 File No. 000-27078
Dear Mr. Bergman:
We have reviewed your response and have th e following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments.
Form 10-K filed on February 22, 2011 for the Fiscal Year Ended December 25, 2010
Part III. Incorporated by Reference in Definitive Proxy Statement filed on April 8, 2011 Compensation Discussion and Analysis, page 15
1. We note your response to comment three of our letter dated May 27, 2011, and we reissue it. Please confirm that in future filings that you will provide the specific EPS performance goals under the LTIP that result in the issuance of restri cted stock or other equity compensation. Please note we are not requesting target disclosure on a prospective basis, rather you should provide the EPS targets in the proxy statement filed after the restricted stock units have vested. Thus, the disclosure of the EPS targets would not be prospective in nature . Please provide us draft di sclosure, though y ou may omit the specific targets in you r supplemental letter.
Stanley M. Bergman Henry Schein, Inc. July 22, 2011 Page 2
Questions may be directed to Edwin S. Ki m at (202) 551-3297 or me at (202) 551-3790 for any issues.
Sincerely,
/s/ John Reynolds John Reynolds
Assistant Director
Show Raw Text
July 22, 2011
Via E-Mail
Stanley M. Bergman, Chief Executive Officer Henry Schein, Inc. 135 Duryea Road Melville, NY 11747
Re: Henry Schein, Inc.
Form 10-K for the Fiscal Year Ended December 25, 2010 Filed February 22, 2011
File No. 000-27078
Dear Mr. Bergman:
We have reviewed your response and have th e following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
Form 10-K filed on February 22, 2011 for the Fiscal Year Ended December 25, 2010
Part III. Incorporated by Reference in Definitive Proxy Statement filed on April 8, 2011
Compensation Discussion and Analysis, page 15
1. We note your response to comment three of our letter dated May 27, 2011, and we
reissue it. Please confirm that in future filings that you will provide the specific EPS
performance goals under the LTIP that result in the issuance of restri cted stock or other
equity compensation. Please note we are not requesting target disclosure on a
prospective basis, rather you should provide the EPS targets in the proxy statement filed
after the restricted stock units have vested. Thus, the disclosure of the EPS targets would
not be prospective in nature . Please provide us draft di sclosure, though y ou may omit the
specific targets in you r supplemental letter.
Stanley M. Bergman
Henry Schein, Inc. July 22, 2011 Page 2
Questions may be directed to Edwin S. Ki m at (202) 551-3297 or me at (202) 551-3790
for any issues.
Sincerely,
/s/ John Reynolds John Reynolds
Assistant Director