SEC Comment Letter for COLUMBIA SPORTSWEAR CO (COLM) (CIK 0001050797) (COLM) — Oct 1, 2020
COLUMBIA SPORTSWEAR CO (COLM) (CIK 0001050797)
Date: Oct. 1, 2020 · CIK: 0001050797 · Accession: 0000000000-20-009242
AI Filing Summary & Sentiment
File numbers found in text: 000-23939
Letter
United States securities and exchange commission logo October 1, 2020 Jim A. Swanson Senior Vice President, Chief Financial Officer Columbia Sportswear Company 14375 Northwest Science Park Drive Portland , Oregon 97229 Re:Columbia Sportswear Company Form 10-Q for the Quarter Ended June 30, 2020 File No. 000-23939 Dear Mr. Swanson: 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 this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q for the Quarter Ended June 30, 2020 Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 24 1.We note that your comparative discussion for changes in your gross profit and selling, general and administrative expense line items identify multiple factors as the source of the changes. Additionally, we note that one of the factors, the increase in inventory reserves, was described as "fairly significant inventory provisions" from your quarterly earnings call. Please revise to quantify the impact of each material factor that you discuss to provide better insight into the underlying reasons behind the changes in your results. Refer to Item 303 of Regulation S-K and Section III.D of SEC Release No. 33-6835. In your response, please provide us with your proposed revisions. In closing, 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.
FirstName LastNameJim A. Swanson Comapany NameColumbia Sportswear Company October 1, 2020 Page 2 FirstName LastName Jim A. Swanson Columbia Sportswear Company October 1, 2020 Page 2 You may contact Heather Clark at (202) 551-3624 or Melissa Raminpour at (202) 551- 3379 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
October 1, 2020
Jim A. Swanson
Senior Vice President, Chief Financial Officer
Columbia Sportswear Company
14375 Northwest Science Park Drive
Portland , Oregon 97229
Re:Columbia Sportswear Company
Form 10-Q for the Quarter Ended June 30, 2020
File No. 000-23939
Dear Mr. Swanson:
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 this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarter Ended June 30, 2020
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 24
1.We note that your comparative discussion for changes in your gross profit and selling,
general and administrative expense line items identify multiple factors as the source of the
changes. Additionally, we note that one of the factors, the increase in inventory reserves,
was described as "fairly significant inventory provisions" from your quarterly earnings
call. Please revise to quantify the impact of each material factor that you discuss to
provide better insight into the underlying reasons behind the changes in your results. Refer
to Item 303 of Regulation S-K and Section III.D of SEC Release No. 33-6835. In your
response, please provide us with your proposed revisions.
In closing, 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.
FirstName LastNameJim A. Swanson
Comapany NameColumbia Sportswear Company
October 1, 2020 Page 2
FirstName LastName
Jim A. Swanson
Columbia Sportswear Company
October 1, 2020
Page 2
You may contact Heather Clark at (202) 551-3624 or Melissa Raminpour at (202) 551-
3379 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing