SEC Company Response from MARINEMAX INC (HZO) (CIK 0001057060) (HZO) — Apr 28, 2014
MARINEMAX INC (HZO) (CIK 0001057060)
Date: April 28, 2014 · CIK: 0001057060 · Accession: 0001193125-14-162248
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-14173
Referenced dates: April 4, 2014
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Attention: William H. Thompson, Accounting Branch Chief Re: MarineMax, Inc. Form 10-K for the Fiscal Year Ended September 30, 2013 Filed December 6, 2013 File No. 001-14173
Dear Mr. Thompson:
On behalf of MarineMax, Inc. (“MarineMax”), I am writing in response to certain telephone conversations over the past few days between Scott Stringer, Staff Accountant, and our counsel at Holland & Knight LLP.
My understanding is that, to assist the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) in its evaluation of the response of MarineMax dated April 4, 2014, the Staff asked that MarineMax provide certain additional information. Specifically, the Staff asked that MarineMax provide cost of sales and gross profit calculations for its products and services under two alternatives: (1) with brokerage reflected in the “Products and Rentals” line item and (2) with brokerage reflected in the “Service” line item. These calculations are presented below.
The below table reflects brokerage in the “Products and Rentals” line items.
Revenue:
Products and Rentals
438,508
479,791
537,045
Service
42,386
44,665
47,452
Total Revenue
480,894
524,456
584,497
Cost of Sales:
Products and Rentals
344,423
374,213
416,488
Service
16,977
16,960
17,156
Total Cost of Sales
361,400
391,173
433,644
Gross Profit:
Products and Rentals
94,085
105,578
120,557
Service
25,409
27,705
30,296
Total Gross Profit
119,494
133,283
150,853
Securities and Exchange Commission
April 28, 2014
Page of 3
The below table reflects brokerage in the “Service” line items.
Revenue:
Products and Rentals
425,951
467,488
523,230
Service
54,943
56,968
61,267
Total Revenue
480,894
524,456
584,497
Cost of Sales:
Products and Rentals
344,423
374,213
416,488
Service
16,977
16,960
17,156
Total Cost of Sales
361,400
391,173
433,644
Gross Profit:
Products and Rentals
81,528
93,275
106,742
Service
37,966
40,008
44,111
Total Gross Profit
119,494
133,283
150,853
Finally, as the Staff considers this information, MarineMax believes it is worth noting that as its industry recovers and boat sales rise (trends MarineMax believes are consistent with recent facts), MarineMax believes the services revenue of MarineMax over the next few years will very likely be less than 10% of its total revenue regardless of how brokerage is classified.
* * *
MarineMax acknowledges the following:
•
MarineMax is responsible for the adequacy and accuracy of the disclosure in its Commission filings;
•
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and
•
MarineMax may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
MarineMax believes that the foregoing responds fully to Mr. Stringer’s verbal requests. Please let us know if you have any questions about our responses.
Securities and Exchange Commission
April 28, 2014
Page of 3
Respectfully submitted,
MarineMax, Inc.
Show Raw Text
CORRESP 1 filename1.htm Correspondence April 28, 2014 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Attention: William H. Thompson, Accounting Branch Chief Re: MarineMax, Inc. Form 10-K for the Fiscal Year Ended September 30, 2013 Filed December 6, 2013 File No. 001-14173 Dear Mr. Thompson: On behalf of MarineMax, Inc. (“MarineMax”), I am writing in response to certain telephone conversations over the past few days between Scott Stringer, Staff Accountant, and our counsel at Holland & Knight LLP. My understanding is that, to assist the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) in its evaluation of the response of MarineMax dated April 4, 2014, the Staff asked that MarineMax provide certain additional information. Specifically, the Staff asked that MarineMax provide cost of sales and gross profit calculations for its products and services under two alternatives: (1) with brokerage reflected in the “Products and Rentals” line item and (2) with brokerage reflected in the “Service” line item. These calculations are presented below. The below table reflects brokerage in the “Products and Rentals” line items. 2011 2012 2013 Revenue: Products and Rentals 438,508 479,791 537,045 Service 42,386 44,665 47,452 Total Revenue 480,894 524,456 584,497 Cost of Sales: Products and Rentals 344,423 374,213 416,488 Service 16,977 16,960 17,156 Total Cost of Sales 361,400 391,173 433,644 Gross Profit: Products and Rentals 94,085 105,578 120,557 Service 25,409 27,705 30,296 Total Gross Profit 119,494 133,283 150,853 Securities and Exchange Commission April 28, 2014 Page 2 of 3 The below table reflects brokerage in the “Service” line items. 2011 2012 2013 Revenue: Products and Rentals 425,951 467,488 523,230 Service 54,943 56,968 61,267 Total Revenue 480,894 524,456 584,497 Cost of Sales: Products and Rentals 344,423 374,213 416,488 Service 16,977 16,960 17,156 Total Cost of Sales 361,400 391,173 433,644 Gross Profit: Products and Rentals 81,528 93,275 106,742 Service 37,966 40,008 44,111 Total Gross Profit 119,494 133,283 150,853 Finally, as the Staff considers this information, MarineMax believes it is worth noting that as its industry recovers and boat sales rise (trends MarineMax believes are consistent with recent facts), MarineMax believes the services revenue of MarineMax over the next few years will very likely be less than 10% of its total revenue regardless of how brokerage is classified. * * * MarineMax acknowledges the following: • MarineMax is responsible for the adequacy and accuracy of the disclosure in its Commission filings; • Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and • MarineMax may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. MarineMax believes that the foregoing responds fully to Mr. Stringer’s verbal requests. Please let us know if you have any questions about our responses. Securities and Exchange Commission April 28, 2014 Page 3 of 3 Respectfully submitted, MarineMax, Inc. By: /s/ Michael H. McLamb Michael H. McLamb Chief Financial Officer cc: William H. McGill, Jr., Chief Executive Officer, MarineMax, Inc. Paulee Day, General Counsel, MarineMax, Inc. Robert J. Grammig, Esq., Holland & Knight LLP Steven W. McMullen, Partner, KPMG LLP