SEC Comment Letter for SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI) — Jun 7, 2007
SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: June 7, 2007 · CIK: 0001092796 · Accession: 0000000000-07-028174
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-141231
Referenced dates: April 10, 2007, April 10, 2007, April 10, 2007
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE Mail Stop 7010 By U.S. Mail and facsimile to (602) 445-8100 Michael F. Golden President and Chief Executive Officer Smith & Wesson Holding Corporation 2100 Roosevelt Avenue Springfield, Massachusetts 01104
Re: Smith & Wesson Holding Corporation Response Letter to Comments Issued April 10, 2007 Regarding Registration Statement on Form S-3 File No. 333-141231 Submitted May 17, 2007
Dear Mr. Golden:
We have limited our review of your filing to those issues we have addressed in our comments below. We welcome any que stions you may have about our comments or any other aspect of our review. Feel free to call us at the te lephone numbers listed at the end of this letter.
General
1. When you file an amendment to your regi stration statement, please disclose your response to prior comment 3.
2. We note your response to comment 4 of our letter dated April 10, 2007. In your amendment, please disclose the proceeds and amount of possible payments as set forth in your response.
3. Please also disclose the tabul ar disclosure provided in response to comment 9 of our April 10, 2007, comment letter.
Table of Contents
4. We note your proposed revisi ons to prior comment 12. Please delete the first
Michael F. Golden Smith & Wesson Holding Corporation June 7, 2007 Page 2 sentence under the About this Prospectus caption or otherwise revise to remove the implication that invest ors are not entitled to rely upon information contained in your public filings that are not incorpor ated by reference into your prospectus or an accompanying prospectus supplement.
Risks Related to the Notes and Common Stock, page 16
5. We note your proposed response to comm ent 14 of our letter dated April 10, 2007. Please expand your disclosure under this risk factor heading to disclose the substance of your responses to comment s 10 and 15 of our prior letter with respect to short sales by the selling shareholders.
Closing Comment
6. Please also review the representations re quested on page of our letter dated April 10, 2007, and provide these representations in the form requested.
Please contact Matt Franker, Staff Attorn ey, at (202) 551-3749 or me at (202) 551-3767 with any questions.
Sincerely,
Jennifer R. Hardy
Branch Chief
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
June 7, 2007
Mail Stop 7010
By U.S. Mail and facsimile to (602) 445-8100
Michael F. Golden
President and Chief Executive Officer
Smith & Wesson Holding Corporation
2100 Roosevelt Avenue
Springfield, Massachusetts 01104
Re: Smith & Wesson Holding Corporation
Response Letter to Comments Issued April 10, 2007
Regarding Registration Statement on Form S-3
File No. 333-141231
Submitted May 17, 2007
Dear Mr. Golden:
We have limited our review of your filing to those issues we have addressed in
our comments below. We welcome any que stions you may have about our comments or
any other aspect of our review. Feel free to call us at the te lephone numbers listed at the
end of this letter.
General
1. When you file an amendment to your regi stration statement, please disclose your
response to prior comment 3.
2. We note your response to comment 4 of our letter dated April 10, 2007. In your
amendment, please disclose the proceeds and amount of possible payments as set
forth in your response.
3. Please also disclose the tabul ar disclosure provided in response to comment 9 of
our April 10, 2007, comment letter.
Table of Contents
4. We note your proposed revisi ons to prior comment 12. Please delete the first
Michael F. Golden
Smith & Wesson Holding Corporation
June 7, 2007 Page 2
sentence under the About this Prospectus caption or otherwise revise to remove
the implication that invest ors are not entitled to rely upon information contained
in your public filings that are not incorpor ated by reference into your prospectus
or an accompanying prospectus supplement.
Risks Related to the Notes and Common Stock, page 16
5. We note your proposed response to comm ent 14 of our letter dated April 10,
2007. Please expand your disclosure under this risk factor heading to disclose the
substance of your responses to comment s 10 and 15 of our prior letter with
respect to short sales by the selling shareholders.
Closing Comment
6. Please also review the representations re quested on page of our letter dated April
10, 2007, and provide these representations in the form requested.
Please contact Matt Franker, Staff Attorn ey, at (202) 551-3749 or me at (202)
551-3767 with any questions.
Sincerely,
Jennifer R. Hardy
Branch Chief
cc: Robert S. Kant
Greenberg Traurig, LLP
2375 East Camelback Road, Suite 700
Phoenix, Arizona 85016