SEC Comment Letter for Childrens Place, Inc. (PLCE) (CIK 0001041859) (PLCE) — Aug 19, 2013
Childrens Place, Inc. (PLCE) (CIK 0001041859)
Date: Aug. 19, 2013 · CIK: 0001041859 · Accession: 0000000000-13-045716
AI Filing Summary & Sentiment
Reasoning
Referenced dates: June 27, 2013
Letter
August 19 , 2013 Via E -mail Jane T. Elfers Chief Executive Officer The Children’s Place Retail Stores, Inc. 500 Plaza Drive Secaucus, NJ 07094
Re: The Children’s Place Retail Stores, Inc. Form s 8-K Filed May 23, 2013 and March 26 , 2013 Definitive Proxy Statement on Schedule 14A Filed April 8, 2013 Response dated July 24, 2013 File No. 000 -23071
Dear Ms. Elfers :
We have reviewed your filing s and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days , by providing the requested information, or by ad vising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing any information you provide in response to these comments, we may have additional comments. Items 2.02 and 9.01 Forms 8 -K filed on May 23, 2013 and March 26, 2013 Exhibit 99.1 Reconciliation of Non-GAAP Financial Information to GAAP Information 1. Since you present non -GAAP net income and income per share, please confirm you w ill disclose how the tax effects of the non-GAAP items were calculated. Please provide us with the draft disclosure you propose to include in future filings.
Jane T. Elfers The Children’s Place Retail Stores, Inc. August 19 , 2013 Page 2
Definitive Proxy Statement on Schedule 14A filed on April 8, 2013
Compensation Discussion and Analysis, page 17
CEO Compensation, page 25
1. We note your response to comment 6 in our letter dated June 27, 2013. Given that the introductory paragraph to your realized compensation disclosure states that Board and Compensation Committee believe that c ompensation should be measured and evaluated on a basis that reflects actual compensation received, please expand the proposed disclosure to explain why you have omitted the amounts included as All Other Compensation in the Summary Compensation Table from Realized Compensation as presented on page 25.
You may conta ct Myra Moosariparambil at (202) 551 -3796 or me at (202) 551 -3871 if you have questions re garding comments on the financial statements and related matters and Adam Turk at (202) 551 -3657 or James Lopez at (202) 551 -3536 with any other questions.
Sincerely,
/s/Tia L. Jenkins
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August 19 , 2013 Via E -mail Jane T. Elfers Chief Executive Officer The Children’s Place Retail Stores, Inc. 500 Plaza Drive Secaucus, NJ 07094 Re: The Children’s Place Retail Stores, Inc. Form s 8-K Filed May 23, 2013 and March 26 , 2013 Definitive Proxy Statement on Schedule 14A Filed April 8, 2013 Response dated July 24, 2013 File No. 000 -23071 Dear Ms. Elfers : We have reviewed your filing s and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days , by providing the requested information, or by ad vising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing any information you provide in response to these comments, we may have additional comments. Items 2.02 and 9.01 Forms 8 -K filed on May 23, 2013 and March 26, 2013 Exhibit 99.1 Reconciliation of Non-GAAP Financial Information to GAAP Information 1. Since you present non -GAAP net income and income per share, please confirm you w ill disclose how the tax effects of the non-GAAP items were calculated. Please provide us with the draft disclosure you propose to include in future filings. Jane T. Elfers The Children’s Place Retail Stores, Inc. August 19 , 2013 Page 2 Definitive Proxy Statement on Schedule 14A filed on April 8, 2013 Compensation Discussion and Analysis, page 17 CEO Compensation, page 25 1. We note your response to comment 6 in our letter dated June 27, 2013. Given that the introductory paragraph to your realized compensation disclosure states that Board and Compensation Committee believe that c ompensation should be measured and evaluated on a basis that reflects actual compensation received, please expand the proposed disclosure to explain why you have omitted the amounts included as All Other Compensation in the Summary Compensation Table from Realized Compensation as presented on page 25. You may conta ct Myra Moosariparambil at (202) 551 -3796 or me at (202) 551 -3871 if you have questions re garding comments on the financial statements and related matters and Adam Turk at (202) 551 -3657 or James Lopez at (202) 551 -3536 with any other questions. Sincerely, /s/Tia L. Jenkins Tia L. Jenkins Senior Assistant Chief Accountant Office of Beve rages, Apparel, and Mining