SEC Comment Letter for Childrens Place, Inc. (PLCE) (CIK 0001041859) (PLCE) — Nov 20, 2007
Childrens Place, Inc. (PLCE) (CIK 0001041859)
Date: Nov. 20, 2007 · CIK: 0001041859 · Accession: 0000000000-07-056737
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 October 17, 2007 Susan J. Riley Executive Vice President, Finance and Administration The Children’s Place Retail Stores, Inc. 915 Secaucus Road Secaucus, NJ 07094
RE: The Children’s Place Retail Stores, Inc. Item 4.01 Form 8-K filed October 15, 2007 File No. 0-23071
Dear Ms. Riley:
We have reviewed your filing a nd have the following comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, 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.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requ irements and to enhance the overall disclosure in your filings. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to contact us at the telephone numbers listed at the end of this letter.
1. We note your disclosure that Deloitte & Touche will continue to provide audit services to you relating to periods prior to fiscal 2007. Please note that you are required to file an amended Form 8-K wh en Deloitte & Touche has completed all audit related work with respect to thei r engagement. We would expect you to disclose the date they completed all audit wor k, and to be able to state, if true, that there were still no disagreements through this date. Also, any new reportable events, or changes in the previously reported reportable events should be described. The amendment should include, as Exhibit 16, another letter from Deloitte & Touche confirming that they agree w ith the updated disclosures, if true. Please acknowledge this obligation to file the Form 8-K amendment.
Susan J. Riley The Children’s Place Retail Stores, Inc. October 17, 2007 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment 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 connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosures 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 this action as a defense in any pro ceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advi sed that the Division of En forcement has access to all information you provide to the staff of the Di vision of Corporation Finance in connection with our review of your filing or in response to our comments on your filing.
As appropriate, and respond to this comment w ithin five business days or tell us when you will provide us with a response. Please pr ovide the representations requested above and submit your response to this comment as an EDGAR correspondence file.
You may contact Robert Burnett, Sta ff Accountant, at ( 202) 551-3330, or in his absence, me at (202) 551-3841 if you ha ve questions regarding this letter.
S i n c e r e l y ,
M i c h a e l M o r a n Branch Chief
Show Raw Text
Mail Stop 3561
October 17, 2007
Susan J. Riley
Executive Vice President, Finance and Administration
The Children’s Place Retail Stores, Inc.
915 Secaucus Road
Secaucus, NJ 07094
RE: The Children’s Place Retail Stores, Inc.
Item 4.01 Form 8-K filed October 15, 2007
File No. 0-23071
Dear Ms. Riley:
We have reviewed your filing a nd have the following comment. Where indicated, we
think you should revise your document in response to this comment. If you disagree, 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.
Please understand that the purpose of our review process is to assist you in your
compliance with the applicable disclosure requ irements and to enhance the overall disclosure
in your filings. We look forward to working with you in these respects. We welcome any
questions you may have about our comment or any other aspect of our review. Feel free to
contact us at the telephone numbers listed at the end of this letter.
1. We note your disclosure that Deloitte & Touche will continue to provide audit
services to you relating to periods prior to fiscal 2007. Please note that you are
required to file an amended Form 8-K wh en Deloitte & Touche has completed all
audit related work with respect to thei r engagement. We would expect you to
disclose the date they completed all audit wor k, and to be able to state, if true, that
there were still no disagreements through this date. Also, any new reportable events, or changes in the previously reported reportable events should be described. The
amendment should include, as Exhibit 16, another letter from Deloitte & Touche
confirming that they agree w ith the updated disclosures, if true. Please acknowledge
this obligation to file the Form 8-K amendment.
Susan J. Riley
The Children’s Place Retail Stores, Inc.
October 17, 2007
Page 2
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings to be certain that the filings include all information required under
the Securities Exchange Act of 1934 and that they have provided all information investors
require for an informed investment 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 connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosures 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 this action as a defense in any pro ceeding initiated by the
Commission or any person under the federal securities laws of the United States.
In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
As appropriate, and respond to this comment w ithin five business days or tell us when
you will provide us with a response. Please pr ovide the representations requested above and
submit your response to this comment as an EDGAR correspondence file.
You may contact Robert Burnett, Sta ff Accountant, at ( 202) 551-3330, or in his
absence, me at (202) 551-3841 if you ha ve questions regarding this letter.
S i n c e r e l y ,
M i c h a e l M o r a n
Branch Chief