SEC Comment Letter for TAPESTRY, INC. (TPR) (CIK 0001116132) (TPR) — Jan 31, 2020
TAPESTRY, INC. (TPR) (CIK 0001116132)
Date: Jan. 31, 2020 · CIK: 0001116132 · Accession: 0000000000-20-000940
AI Filing Summary & Sentiment
File numbers found in text: 001-16153
Letter
January 31, 2020 Brian Satenstein Corporate Controller Tapestry, Inc. 10 Hudson Yards New York, NY 10001 Re:Tapestry, Inc. Form 10-K for the Fiscal Year Ended June 29, 2019 Filed August 15, 2019 File No. 001-16153 Dear Mr. Satenstein: We have reviewed your filing 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 comment applies 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-K for the Fiscal Year Ended June 29, 2019 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 29 1.Your narrative of the year-to-year fluctuations, in the summary and segment performance sections, consistently use the phrase “excluding non-GAAP charges” to refer to the expenses incurred for ERP implementation, integration and acquisition, and the impact of the tax legislation that you excluded as adjustments in your GAAP to Non-GAAP reconciliation. It appears to us that your use of this phrase may be confusing to an investor since the items you are excluding are not non-GAAP charges, but rather certain significant items affecting the comparability of your results of operations. Please revise future filings to eliminate the use of the term “non-GAAP charges” where you discuss the results of operations between periods, and characterize the nature of such charges differently. 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 LastNameBrian Satenstein Comapany NameTapestry, Inc. January 31, 2020 Page 2 FirstName LastName Brian Satenstein Tapestry, Inc. January 31, 2020 Page 2 You may contact Dale Welcome at 202-551-3865 or John Cash at 202-551-3768 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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January 31, 2020
Brian Satenstein
Corporate Controller
Tapestry, Inc.
10 Hudson Yards
New York, NY 10001
Re:Tapestry, Inc.
Form 10-K for the Fiscal Year Ended June 29, 2019
Filed August 15, 2019
File No. 001-16153
Dear Mr. Satenstein:
We have reviewed your filing 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
comment applies 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-K for the Fiscal Year Ended June 29, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 29
1.Your narrative of the year-to-year fluctuations, in the summary and segment performance
sections, consistently use the phrase “excluding non-GAAP charges” to refer to the
expenses incurred for ERP implementation, integration and acquisition, and the impact of
the tax legislation that you excluded as adjustments in your GAAP to Non-GAAP
reconciliation. It appears to us that your use of this phrase may be confusing to an investor
since the items you are excluding are not non-GAAP charges, but rather certain significant
items affecting the comparability of your results of operations. Please revise future filings
to eliminate the use of the term “non-GAAP charges” where you discuss the results of
operations between periods, and characterize the nature of such charges differently.
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 LastNameBrian Satenstein
Comapany NameTapestry, Inc.
January 31, 2020 Page 2
FirstName LastName
Brian Satenstein
Tapestry, Inc.
January 31, 2020
Page 2
You may contact Dale Welcome at 202-551-3865 or John Cash at 202-551-3768 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing