SEC Comment Letter for LENNOX INTERNATIONAL INC (LII) (CIK 0001069202) (LII) — Jul 27, 2009
LENNOX INTERNATIONAL INC (LII) (CIK 0001069202)
Date: July 27, 2009 · CIK: 0001069202 · Accession: 0000000000-09-039786
AI Filing Summary & Sentiment
Referenced dates: July 20, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631
DIVISION OF CORPORATION FINANCE
VIA FACSIMILE AND U.S. MAIL
July 24, 2009 Roy A. Rumbough Chief Financial Officer Lennox International, Inc. 2140 Lake Park Blvd. Richardson, Texas 75080 RE: Lennox International, Inc. Form 10-K for Fiscal Year Ended December 31, 2008 Forms 10-Q for Fiscal Quarter Ended March 31, 2009 Definitive Proxy Statement filed April 17, 2009 File No. 1-15149 Dear Mr. Rumbough:
We have reviewed your letter filed July 21, 2009 and have the following comment. Where indicated, we think you should revise your disclosures in response to this comment. If you disagree, we will cons ider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosu re requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the phone numbers listed below.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008
Item 15 – Exhibits, Financial Statement Schedules, page 96
1. We note your response to comment 1 of our letter dated July 20, 2009. Please be advised that you may redact informati on from your filing pursuant to an application for confidential treatment filed under Exchange Act Rule 24b-2 and that Rule 24b-2 sets forth the exclusiv e means for obtaining confidential treatment of information contained in a documen t filed that would be exempt from disclosure under the Freedom of Information Act. Failure to comply with either the substantive or procedur al aspects of the Commissi on's confidential treatment process may result in a denial of an application.
Mr. Roy A. Rumbough July 24, 2009 Page 2 * * * *
Please respond to this comment within 10 business days, or tell us when you will provide us with a response. Please provide us with a response letter that keys your response to our comment and provides any requested information. Detailed letters greatly facilitate our review . Please file your response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your response to our comment. You may contact Chambre Malone, Atto rney, at (202) 551-3262 or, in her absence, Jay Ingram, Legal Branch Chief, at (202) 551-3397 if you have any questions regarding legal matters. Please contact Erne st Greene, Staff Accountant, at (202) 551- 3733 or, in his absence, the undersigned at (202) 551-3689, if you have questions regarding comments on the financial statements and related matters. Sincerely, John Hartz S e n i o r A s s i s t a n t Chief Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
VIA FACSIMILE AND U.S. MAIL
July 24, 2009
Roy A. Rumbough Chief Financial Officer Lennox International, Inc. 2140 Lake Park Blvd. Richardson, Texas 75080
RE: Lennox International, Inc.
Form 10-K for Fiscal Year Ended December 31, 2008
Forms 10-Q for Fiscal Quarter Ended March 31, 2009
Definitive Proxy Statement filed April 17, 2009 File No. 1-15149
Dear Mr. Rumbough:
We have reviewed your letter filed July 21, 2009 and have the following
comment. Where indicated, we think you should revise your disclosures in response to
this comment. If you disagree, we will cons ider your explanation as to why our comment
is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your
explanation. Please understand that the purpose of our review process is to assist you in
your compliance with the applicable disclosu re requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or on any other aspect of our
review. Feel free to call us at the phone numbers listed below.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008
Item 15 – Exhibits, Financial Statement Schedules, page 96
1. We note your response to comment 1 of our letter dated July 20, 2009. Please be
advised that you may redact informati on from your filing pursuant to an
application for confidential treatment filed under Exchange Act Rule 24b-2 and
that Rule 24b-2 sets forth the exclusiv e means for obtaining confidential treatment
of information contained in a documen t filed that would be exempt from
disclosure under the Freedom of Information Act. Failure to comply with either the substantive or procedur al aspects of the Commissi on's confidential treatment
process may result in a denial of an application.
Mr. Roy A. Rumbough
July 24, 2009 Page 2
* * * *
Please respond to this comment within 10 business days, or tell us when you will
provide us with a response. Please provide us with a response letter that keys your
response to our comment and provides any requested information. Detailed letters
greatly facilitate our review . Please file your response on EDGAR as a correspondence
file. Please understand that we may have additional comments after reviewing your
response to our comment.
You may contact Chambre Malone, Atto rney, at (202) 551-3262 or, in her
absence, Jay Ingram, Legal Branch Chief, at (202) 551-3397 if you have any questions
regarding legal matters. Please contact Erne st Greene, Staff Accountant, at (202) 551-
3733 or, in his absence, the undersigned at (202) 551-3689, if you have questions
regarding comments on the financial statements and related matters.
Sincerely, John Hartz
S e n i o r A s s i s t a n t
Chief Accountant