SEC Company Response from PC CONNECTION INC (CNXN) (CIK 0001050377) (CNXN) — Mar 23, 2010
PC CONNECTION INC (CNXN) (CIK 0001050377)
Date: March 23, 2010 · CIK: 0001050377 · Accession: 0001193125-10-064147
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 31, 2009, January 11, 2010
Letter
United States Securities and Exchange Commission PC Connection, Inc. Annual Report on Form 10-K for the Year Ended December 31, 2008, Filed March 16, 2009 File No. 0-23827, and Related Filings
RE:
Dear Mr. Fieldsend:
This letter supplements our letter dated January 11, 2010 referring to your letter dated December 31, 2009, commenting on our 2008 Form 10-K filing and our various 2009 filings. Your letter requires that we respond within 10 business days (which I calculate to be Friday, January 15) or advise you when we will respond. I have been reviewing the SEC’s comments relating to those filings, and my staff and I have been busy planning, gathering necessary information and otherwise working on creating appropriate responses.
I have also, however, reviewed the band-width of my staff during this busy year-end financial close and have determined that we will need additional time to provide adequate responses. We are all heavily occupied in closing the books, working with the auditors and finalizing our 2009 financial results, which we will be initially reporting in our press release on February 4. Accordingly, I request that we be granted until February 12 to complete and submit our responses to your December 31 letter. I noted that most of the comments relate to prospective disclosure changes, and those changes will be incorporated in our 2009 Form 10-K report and 2010 Proxy Statement. I assure you that we will try to respond earlier if we can, and we can most certainly file the amended 8-K report, containing the schedules and exhibits requested in your comment no. 2, well before that date.
I was able to discuss this matter with you on January 12, at which time you indicated that our requested extension to February 12 was acceptable. I assure you that we will respond to all of the comments in your December 31, 2009 letter at least by February 12, 2010, if not sooner. If you have any questions or additional comments, I can be reached by telephone at (603) 683-2156 or (603) 859-0134, or by fax to my assistant, Janice Rush, at (603) 683-1334. You may also contact Stephen Baldridge, our Corporate Controller, at (603) 683-2052.
Thank you for your assistance.
Yours truly,
/s/ Jack L. Ferguson
Jack L. Ferguson
Executive Vice President and CFO
JLF:jar
cc: H. Christopher Owings, Assistant Director
Stephen Baldridge, Sr. Vice President of Finance & Corporate Controller
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CORRESP 1 filename1.htm Correspondence January 14, 2010 Via facsimile (202-772-9204) and US Mail John Fieldsend, Attorney-Advisor United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 RE: PC Connection, Inc. Annual Report on Form 10-K for the Year Ended December 31, 2008, Filed March 16, 2009 File No. 0-23827, and Related Filings Dear Mr. Fieldsend: This letter supplements our letter dated January 11, 2010 referring to your letter dated December 31, 2009, commenting on our 2008 Form 10-K filing and our various 2009 filings. Your letter requires that we respond within 10 business days (which I calculate to be Friday, January 15) or advise you when we will respond. I have been reviewing the SEC’s comments relating to those filings, and my staff and I have been busy planning, gathering necessary information and otherwise working on creating appropriate responses. I have also, however, reviewed the band-width of my staff during this busy year-end financial close and have determined that we will need additional time to provide adequate responses. We are all heavily occupied in closing the books, working with the auditors and finalizing our 2009 financial results, which we will be initially reporting in our press release on February 4. Accordingly, I request that we be granted until February 12 to complete and submit our responses to your December 31 letter. I noted that most of the comments relate to prospective disclosure changes, and those changes will be incorporated in our 2009 Form 10-K report and 2010 Proxy Statement. I assure you that we will try to respond earlier if we can, and we can most certainly file the amended 8-K report, containing the schedules and exhibits requested in your comment no. 2, well before that date. I was able to discuss this matter with you on January 12, at which time you indicated that our requested extension to February 12 was acceptable. I assure you that we will respond to all of the comments in your December 31, 2009 letter at least by February 12, 2010, if not sooner. If you have any questions or additional comments, I can be reached by telephone at (603) 683-2156 or (603) 859-0134, or by fax to my assistant, Janice Rush, at (603) 683-1334. You may also contact Stephen Baldridge, our Corporate Controller, at (603) 683-2052. Thank you for your assistance. Yours truly, /s/ Jack L. Ferguson Jack L. Ferguson Executive Vice President and CFO JLF:jar cc: H. Christopher Owings, Assistant Director Stephen Baldridge, Sr. Vice President of Finance & Corporate Controller