SEC Comment Letter for HENRY SCHEIN INC (HSIC) (CIK 0001000228) (HSIC) — Apr 29, 2016
HENRY SCHEIN INC (HSIC) (CIK 0001000228)
Date: April 29, 2016 · CIK: 0001000228 · Accession: 0000000000-16-074358
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Mail Stop 3561 April 29, 2016 Via E -mail Steven Paladino Executive Vice President and Chief Financial Officer Henry Schein , Inc. 135 Duryea Road Melville , NY 11747 Re: Henry Schein, Inc. Form 10-K for the Fis cal Year Ended December 26, 2015 Response dated April 21, 2016 File No. 0 -27078 Dear Mr. Paladino : We have reviewed your April 21, 2016 response to our comment letter and have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Form 10 -K for the Fiscal Year Ended December 26, 2015 Consolidated Financial Sta tements Note 15. Segment and Geographic Data, page 96 1. We reviewed your response dated April 21, 2016, which discusses additional factors you considered in determining your dental, animal health and medical operating segments are economically similar. For each period provided in your last response, please provide us with each operating segment’s operating income as a percentage of sales, adjusted for only amortization and direct acquisition charges. Please include the operating results of your acquisitio ns in each segment’s operating income as a percentage of sales. For each period presented, please also separately tell us, by operating segment, the portion of the adjustment that relates to (a) amortization and (b) direct acquisition charges. Steven Paladino Henry Schein, Inc. April 29 , 2016 Page 2 You may contact Linda Cvrkel at (202) 551-3813 or me at (202) 551-3769 with any questions. Sincerely, /s/ Rufus Decker Rufus Decker Accounting Branch Chief Office of Beverages, Apparel and Mining