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SEC Comment Letter for PC CONNECTION INC (CNXN) (CIK 0001050377) (CNXN) — Feb 20, 2008

PC CONNECTION INC (CNXN) (CIK 0001050377)
Date: Feb. 20, 2008 · CIK: 0001050377 · Accession: 0000000000-08-008991

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: December 31, 2007, February 8, 2008

Date
February 20, 2008
Author
H. Christopher Owings
Form
UPLOAD
Company
PC CONNECTION INC (CNXN) (CIK 0001050377)

Letter

Mail Stop 3561 February 20, 2008 Patricia Gallup Chairman and Chief Executive Officer PC Connection, Inc. Rt. 101A, 730 Milford Road Merrimack, NH 03054 Re: PC Connection, Inc. Form 10-K for Fiscal Year Ended December 31, 2006 Filed March 28, 2007 Definitive Proxy Statement on Schedule 14A Filed April 30, 2007 File No. 0-23827 Dear Ms. Gallup: We have reviewed your response letter dated February 8, 2008 and have the following comments. You should comply with the comments in all future filings, as applicable. Please confirm in writing that you will do so, and also explain to us how you intend to comply. If you disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. After reviewing this inform ation, we may raise additional comments. Executive Compensation

Compensation Discussion and Analysis, page 10 1. We note your response to prior comment ei ght from our letter dated December 31, 2007. Please provide us with the proposed di sclosure in response to this comment using the “current initiative s and stated goals” for the fiscal year ended December 31, 2007.

Patricia Gallup PC Connection, Inc. February 20, 2008 Page 2 Executive Bonus Plan, page 12

2. We note your response to prior comment 10 from our letter dated December 31, 2007. Please provide us with the proposed di sclosure in response to this comment with respect to the fiscal year ended December 31, 2007. 3. We note your response to prior comment 11 from our letter dated December 31, 2007. You refer us to your response to comments 8 and 10, however, those responses would appear to address cor porate goals, not individual ones. Please articulate the individual goa ls related to awards unde r the executive bonus plan you rely upon and state whether they were achieved in 2007.

*****

Please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Blair Petrillo, Staff Attorney, at (202) 551-3550 or Mara Ransom, Legal Branch Chief, at (202) 551-3264 or me at (202) 551-3720 with any questions. Sincerely,

H. Christopher Owings Assistant Director

Show Raw Text
Mail Stop 3561                   February 20, 2008   Patricia Gallup Chairman and Chief Executive Officer PC Connection, Inc. Rt. 101A, 730 Milford Road Merrimack, NH  03054
 Re:  PC Connection, Inc.
  Form 10-K for Fiscal Year Ended December 31, 2006
  Filed March 28, 2007   Definitive Proxy Statement on Schedule 14A   Filed April 30, 2007   File No. 0-23827
Dear Ms. Gallup:
  We have reviewed your response letter  dated February 8, 2008 and have the
following comments.  You should comply with the comments in all future filings, as applicable.  Please confirm in writing that you will do so, and also explain to us how you
intend to comply.  If you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is  unnecessary.  Please be as detailed as
necessary in your explanation.  After reviewing this inform ation, we may raise additional
comments.
Executive Compensation

Compensation Discussion and Analysis, page 10
1. We note your response to prior comment ei ght from our letter  dated December 31,
2007.  Please provide us with the proposed di sclosure in response to this comment
using the “current initiative s and stated goals” for the fiscal year ended December
31, 2007.

Patricia Gallup
PC Connection, Inc.
February 20, 2008 Page 2   Executive Bonus Plan, page 12

2. We note your response to prior comment  10 from our letter dated December 31,
2007.  Please provide us with the proposed di sclosure in response to this comment
with respect to the fiscal  year ended December 31, 2007.
3. We note your response to prior comment  11 from our letter dated December 31,
2007.  You refer us to your response to comments 8 and 10, however, those responses would appear to address cor porate goals, not individual ones.  Please
articulate the individual goa ls related to awards unde r the executive bonus plan
you rely upon and state whether they were achieved in 2007.

*****

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
responses to our comments.
 You may contact Blair Petrillo, Staff Attorney, at (202) 551-3550 or Mara
Ransom, Legal Branch Chief, at (202) 551-3264 or me at (202) 551-3720 with any
questions.
Sincerely,

H. Christopher Owings Assistant Director