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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

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
April 29, 2016
Author
/s/ Rufus Decker
Form
UPLOAD
Company
HENRY SCHEIN INC (HSIC) (CIK 0001000228)

Letter

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

Show Raw Text
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