SEC Comment Letter for SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796) (SWBI) — Feb 1, 2013
SMITH & WESSON BRANDS, INC. (SWBI) (CIK 0001092796)
Date: Feb. 1, 2013 · CIK: 0001092796 · Accession: 0000000000-13-005882
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 15, 2013, January 29, 2013
Letter
January 31 , 2013 Via E -mail Mr. Jeffrey D. Buchanan Executive Vice President, Chief Financial Officer, and Treasurer Smith & Wesson Holding Corporation 2100 Roosevelt Avenue Springfield, MA 01104
RE: Smith & Wesson Holding Corporation Form 10 -K for the Year ended April 30, 2012 Filed June 28, 2012 Response dated January 29, 2013 File No. 1-31552
Dear Mr. Buchanan :
We have reviewed your response letter dated January 29, 2013 and have the following additional comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances , please tell us why in your response.
After reviewing the information you provide in response to this comm ent, we may have additional comments.
Item 15 – Exhibits and Financial Statement Schedules, page 39
Consolidated Financial Statements, page F -1
Note 2 – Significant Accounting Policies, page F -8
General
1. We have reviewed your response to p rior comment six from our letter dated January 15, 2013. Please also disclose in future filings the types of expenses that you include in the general and administrative expenses line item. Please show us supplementally what your revised disclosure will l ook like.
Mr. Jeffrey D. Buchanan Smith & Wesson Holding Corporation January 31 , 2013 Page 2
You may contact Leland Benton , Staff Attorney, at (202) 551 -3791 or, in his absence, Jay Ingram, Legal Branch Chief, at (202) 551 -3397 if you have any questions regarding legal or disclosure matters. Please contact Jeffrey Gordon, Staff Accountant, at (202) 551 -3866 or, in his absence, the undersigned at (202) 551 -3769 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Rufus Decker
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January 31 , 2013 Via E -mail Mr. Jeffrey D. Buchanan Executive Vice President, Chief Financial Officer, and Treasurer Smith & Wesson Holding Corporation 2100 Roosevelt Avenue Springfield, MA 01104 RE: Smith & Wesson Holding Corporation Form 10 -K for the Year ended April 30, 2012 Filed June 28, 2012 Response dated January 29, 2013 File No. 1-31552 Dear Mr. Buchanan : We have reviewed your response letter dated January 29, 2013 and have the following additional comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances , please tell us why in your response. After reviewing the information you provide in response to this comm ent, we may have additional comments. Item 15 – Exhibits and Financial Statement Schedules, page 39 Consolidated Financial Statements, page F -1 Note 2 – Significant Accounting Policies, page F -8 General 1. We have reviewed your response to p rior comment six from our letter dated January 15, 2013. Please also disclose in future filings the types of expenses that you include in the general and administrative expenses line item. Please show us supplementally what your revised disclosure will l ook like. Mr. Jeffrey D. Buchanan Smith & Wesson Holding Corporation January 31 , 2013 Page 2 You may contact Leland Benton , Staff Attorney, at (202) 551 -3791 or, in his absence, Jay Ingram, Legal Branch Chief, at (202) 551 -3397 if you have any questions regarding legal or disclosure matters. Please contact Jeffrey Gordon, Staff Accountant, at (202) 551 -3866 or, in his absence, the undersigned at (202) 551 -3769 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Rufus Decker Rufus Decker Accounting Branch Chief