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SEC Comment Letter for HENRY SCHEIN INC (HSIC) (CIK 0001000228) (HSIC) — Mar 13, 2012

HENRY SCHEIN INC (HSIC) (CIK 0001000228)
Date: March 13, 2012 · CIK: 0001000228 · Accession: 0000000000-12-012796

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File numbers found in text: 000-27078

Date
March 13, 2012
Author
Tia L. Jenkins
Form
UPLOAD
Company
HENRY SCHEIN INC (HSIC) (CIK 0001000228)

Letter

March 13, 2012 Via E-mail Steven Paladino Chief Financial Officer Henry Schein, Inc. 135 Duryea Road Melville, New York 11747 Re: Henry Schein, Inc. Form 10-K for Fiscal Year Ended December 31, 2011 Filed February 15, 2012 File No. 000-27078

Dear Mr. Paladino: We have reviewed your filing and have the 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 for Fiscal Year Ended December 31, 2011

Notes to Consolidated Financial Statements

Note 1 – Significant Accounting Policies

Revenue Recognition, page 60

1. It appears from your disclosure on page 66 you adopted the provisions of ASU 2009-13 in December 2010 as it relates to revenue recognition for multiple element arrangements. Please tell us how you have applied the guidance at FSAB ASC 605-25-30-2 in determining your accounting policy for the revenue recognition for multiple-element arrangements. Please provide us with and confirm in future Exchange Act filings you will include, disclosures requi red by FASB ASC 605-25-50-2.

Steven Paladino Henry Schein, Inc. March 13, 2012 Page 2

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provi de a written statement from the company acknowledging that:  the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of the United States.

You may contact Suying Li at (202) 551-3335 or Angela Ha lac at (202) 551-3398 if you have questions regarding comments on the fina ncial statements and related matters.

Sincerely, /s/Tia L. Jenkins
Tia L. Jenkins
Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining

Show Raw Text
March 13, 2012
 Via E-mail

Steven Paladino Chief Financial Officer Henry Schein, Inc.
135 Duryea Road
Melville, New York 11747
Re: Henry Schein, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2011
Filed February 15, 2012 File No. 000-27078

Dear Mr. Paladino:
 We have reviewed your filing and have the 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 for Fiscal Year Ended December 31, 2011

 Notes to Consolidated Financial Statements

 Note 1 – Significant Accounting Policies

 Revenue Recognition, page 60

 1. It appears from your disclosure on page 66 you adopted the provisions of ASU 2009-13
in December 2010 as it relates to revenue recognition for multiple element arrangements.  Please tell us how you have applied the guidance at FSAB ASC 605-25-30-2 in
determining your accounting policy for the revenue recognition for multiple-element arrangements.  Please provide us with and confirm in future Exchange Act filings you will include, disclosures requi red by FASB ASC 605-25-50-2.

Steven Paladino Henry Schein, Inc. March 13, 2012 Page 2

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Suying Li at (202) 551-3335 or Angela Ha lac at (202) 551-3398 if you
have questions regarding comments on the fina ncial statements and related matters.

Sincerely,  /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant Office of Beverages, Apparel and Mining