SEC Comment Letter for Childrens Place, Inc. (PLCE) (CIK 0001041859) (PLCE) — Jun 29, 2017
Childrens Place, Inc. (PLCE) (CIK 0001041859)
Date: June 29, 2017 · CIK: 0001041859 · Accession: 0000000000-17-022868
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 June 29 , 2017 Via E -mail Mr. Anurup Pruthi Chief Financial Officer The Children’s Place , Inc. 500 Plaza Drive Secaucus, New Jersey 07094
Re: The Children’s Place, Inc. Form 10-K for the Fiscal Year Ended January 28, 2017 Filed March 23 , 2017 File No. 000 -23071
Dear Mr. Pruthi :
We have limited our review of your filing to the financial statements and related disclosures 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 the comment within ten busines s days by provi ding the requested information or advise us as soon as possible when you wil l respond . If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response.
After reviewing you r response to the comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended January 28, 2017
Item 7 - Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of operations, page 34
1. We note that you include e -commerce sales in your determination of comparable retail sales and that you attribute increases to your revenues for both the year ended January 28, 2017 and the thirteen weeks ended April 29, 2017 to the growth in this metric. To the extent that e -commerce sales have a measurable effect on your comparable retail sales, please quantify your e -commerce sales or provide transparent disclosure regarding the impacts that e -commerce sales had on your comparable retail sales metric.
Mr. Anurup Pruthi Children’s Place, Inc. June 29, 2017 Page 2
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.
You may contact Raj Rajan at 202-551-3388 or me at 202 -551-3650 with any questions.
Sincerely,
/s/Craig Arakawa
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Mail Stop 3561
June 29 , 2017
Via E -mail
Mr. Anurup Pruthi
Chief Financial Officer
The Children’s Place , Inc.
500 Plaza Drive
Secaucus, New Jersey 07094
Re: The Children’s Place, Inc.
Form 10-K for the Fiscal Year Ended January 28, 2017
Filed March 23 , 2017
File No. 000 -23071
Dear Mr. Pruthi :
We have limited our review of your filing to the financial statements and related
disclosures 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 the comment within ten busines s days by provi ding the requested
information or advise us as soon as possible when you wil l respond . If you do not believe our
comment applies to your facts a nd circumstances, please tell us why in your response.
After reviewing you r response to the comment , we may have additional comments.
Form 10 -K for the Fiscal Year Ended January 28, 2017
Item 7 - Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Results of operations, page 34
1. We note that you include e -commerce sales in your determination of comparable retail
sales and that you attribute increases to your revenues for both the year ended January 28,
2017 and the thirteen weeks ended April 29, 2017 to the growth in this metric. To the
extent that e -commerce sales have a measurable effect on your comparable retail sales,
please quantify your e -commerce sales or provide transparent disclosure regarding the
impacts that e -commerce sales had on your comparable retail sales metric.
Mr. Anurup Pruthi
Children’s Place, Inc.
June 29, 2017
Page 2
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.
You may contact Raj Rajan at 202-551-3388 or me at 202 -551-3650 with any questions.
Sincerely,
/s/Craig Arakawa
Craig Arakawa
Accounting Branch Chief
Office of Beverages, Apparel and
Mining