SEC Comment Letter for TUPPERWARE BRANDS CORP (TUP) (CIK 0001008654) — Aug 17, 2005
TUPPERWARE BRANDS CORP (TUP) (CIK 0001008654)
Date: Aug. 17, 2005 · CIK: 0001008654 · Accession: 0000000000-05-042595
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Mail Stop 7010
August 17, 2005
Mr. Michael S. Poteshman
Executive Vice President and CFO
Tupperware Corporation
14901 South Orange Blossom Trail
Orlando, FL 32837
RE: Form 10-K for the fiscal year ended December 25, 2004
Form 10-Q for the quarter ended April 2, 2005
Form 10-Q for the quarter ended July 2, 2005
File No. 1-11657
Dear Mr. Poteshman:
We have reviewed these filings and have the following
comments.
If you disagree with a comment, we will consider your explanation
as
to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation. In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure. After reviewing this
information,
we may or may not raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
FORM 10-Q FOR THE PERIOD ENDED JULY 2, 2005
General
Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like. These revisions should be
included in your future filings.
Financial Statements
Note 2 - Shipping and Handling Costs, page 7
Please disclose the amount of distribution costs that are included
in
the delivery, sales and administrative expense line item for each
period presented as you agreed to do in your July 27, 2005
supplemental response to us.
Note 3 - Promotional Accruals, page 7
Please disclose the amount of promotional expenses that are
included
in the delivery, sales and administrative expense line item for
each
period presented as you agreed to do in your July 27, 2005
supplemental response to us.
* * * *
Please respond to these comments within 10 business days, or
tell us when you will provide us with a response. Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information. Detailed letters greatly
facilitate our review. Please file your supplemental response on
EDGAR as a correspondence file. Please understand that we may
have
additional comments after reviewing your responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information required under the
Securities Exchange Act of 1934 and that they have provided all
information investors require for an informed decision. 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 addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.
If you have any questions regarding these comments, please
direct them to Jeffrey Gordon, Staff Accountant, at (202) 551-3866
or, in his absence, to the undersigned at (202) 551-3769.
Sincerely,
Rufus Decker
Accounting Branch Chief
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Mr. Michael S. Poteshman
Tupperware Corporation
August 17, 2005
Page 1 of 3
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
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