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SEC Comment Letter for LIFECORE BIOMEDICAL, INC. \DE\ (LFCR) (CIK 0001005286) (LFCR) — Feb 16, 2018

LIFECORE BIOMEDICAL, INC. \DE\ (LFCR) (CIK 0001005286)
Date: Feb. 16, 2018 · CIK: 0001005286 · Accession: 0000000000-18-005421

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
February 16, 2018
Author
Vice President
Form
UPLOAD
Company
LIFECORE BIOMEDICAL, INC. \DE\ (LFCR) (CIK 0001005286)

Letter

February 16, 2018 Mail Stop 4631 Via E -mail Gregory S. Skinner Vice President Landec Corporation 3603 Haven Avenue Menlo Park, CA 94025

Re: Landec Corporation Form 10-K/A for Fiscal Year Ended May 28, 2017 Filed August 15, 2017 File No. 0-27446

Dear Mr. Skinner:

We have reviewed your filing an d have the following comment s. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments.

Form 10 -K/A for Fiscal Year Ended May 28, 2017

Pursuant to Rule 12b -15 of Regulation 12B, amendments filed pursuant to this section must set forth the complete text of each item as amended. I n the explanatory note of your amended filing, you state that this amendment was filed to correct a typographical e rror in the date of the Opinion. A ccordingly, the entirety of Item 8 for which the Opinion i s a part, inclusive of a full set of financial statements and accompanying notes, must be in cluded in your amended filing. Please file an amended filing that co mplies with the cited guidance. P lease also include appropriately revised certifications.

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Gregory S. Skinner Landec Corporation February 16, 2018 Page 2

You may contact Tracie Mariner , Senior Staff Accountant , at (202) 551 -3744 , or Jeanne Baker, Assistant Chief Accountant, at (202) 551 -3691, if you have questions regarding comments on the financial s tatements and related matters. You may contact me at (2 02) 551- 3355 with any other questions.

Sincere ly,

/s/ Terence O ’Brien

Terence O’Brien Branch Chief Office of Manufacturing and Construction

Show Raw Text
February 16, 2018

Mail Stop 4631

Via E -mail
Gregory S. Skinner
Vice President
Landec Corporation
3603 Haven Avenue
Menlo Park, CA 94025

Re: Landec Corporation
 Form 10-K/A for Fiscal  Year Ended  May 28, 2017
Filed  August 15, 2017
File No. 0-27446

Dear  Mr. Skinner:

We have reviewed your filing an d have the following comment s.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  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
comments apply to your facts and circumstances, please tell us  why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K/A for Fiscal Year Ended May 28, 2017

Pursuant to Rule 12b -15 of Regulation 12B, amendments filed pursuant to this section must set
forth the complete text of each item  as amended.  I n the explanatory note of your amended filing,
you state that this amendment was filed to correct a typographical e rror in the date of the
Opinion.  A ccordingly, the entirety of Item 8 for which the Opinion i s a part, inclusive of a full
set of financial statements and accompanying notes, must be in cluded in your amended filing.
Please file an amended filing that co mplies with the cited guidance.  P lease also include
appropriately revised certifications.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Gregory S. Skinner
Landec  Corporation
February 16, 2018
Page 2

 You may contact Tracie Mariner , Senior Staff Accountant , at (202) 551 -3744 , or Jeanne
Baker, Assistant Chief Accountant, at (202) 551 -3691,  if you have questions regarding
comments on the financial s tatements and related matters. You may contact  me at (2 02) 551-
3355  with any other questions.

Sincere ly,

 /s/ Terence O ’Brien

 Terence O’Brien
Branch Chief
Office of Manufacturing and
Construction