SEC Comment Letter for ENODIS PLC (CIK 0001116547) — Apr 18, 2005
ENODIS PLC (CIK 0001116547)
Date: April 18, 2005 · CIK: 0001116547 · Accession: 0000000000-05-018811
AI Filing Summary & Sentiment
Referenced dates: April 14, 2005
Letter
April 18, 2005 via U.S. mail and facsimile David S. McCulloch, Chief Executive Officer Enodis PLC 2227 Welbilt Boulevard New Port Richey, FL 34655
RE: Form 20-F for the fiscal year ended October 2, 2004 File No. 1-15032
Dear Mr. McCulloch:
We have reviewed your response letter dated April 14, 2005 and have the following additional comments. If you disagree, we will consider your explanation as to why our comment is inapplicable. In some of our comments, we may ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments.
FORM 20-F FOR THE YEAR ENDED OCTOBER 2, 2004
Comment applicable to your overall filing 1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like. Some of our comments refer to US GAAP literature. If your accounting under UK GAAP differs from your accounting under US GAAP, please also show us the additional disclosures that will be included in your US GAAP reconciliation footnote. These revisions should be included in your future filings beginning to the extent practical with your report of Form 6-K announcing results for the 26 weeks ending about April 2, 2005.
Item 3. Key Information
Selected Financial Data, page 2 2. Based on your response to our comment 2, we would not object to your suggestion regarding only including the ADS information in the Selected Financial Data.
Financial Statements
2. Accounting policies, page F-8 3. We have read your response to our comments 11 and 12. Please expand your disclosure to specify which line item within operating profit/(loss) your licensing costs and shipping, handling, inspection and distribution costs incurred by you are included. If you currently exclude these shipping related costs from food equipment costs, please disclose: * in a footnote the line items that these excluded costs are included in and the amounts included in each line item for each period presented, and * in MD&A that your gross margins may not be comparable to those of other entities, since some entities include these costs in cost of sales and others like you exclude these costs from gross margin, including them instead in a line item, such as corporate costs. Refer to paragraph 6 of EITF 00-10.
28. Supplementary Information for U.S. Investors
Consolidated Statements of Cash Flows, page F-54 4. We have read your response to our comment 17. It appears as though the detail relating to operating activities was excluded. Ensure this information is included in your disclosure in future filings.
* * * *
As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comments and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please direct them to Meagan Caldwell, Staff Accountant, at (202) 824- or, in her absence, Nathan Cheney, Assistant Chief Accountant, at (202)942-1804.
Sincerely,
John Hartz
Senior Assistant Chief
Accountant
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<TEXT>
April 18, 2005
via U.S. mail and facsimile
David S. McCulloch, Chief Executive Officer
Enodis PLC
2227 Welbilt Boulevard
New Port Richey, FL 34655
RE: Form 20-F for the fiscal year ended October 2, 2004
File No. 1-15032
Dear Mr. McCulloch:
We have reviewed your response letter dated April 14, 2005
and
have the following additional comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable.
In
some of our comments, we may ask you to provide us with
supplemental
information so we may better understand your disclosure. After
reviewing this information, we may or may not raise additional
comments.
FORM 20-F FOR THE YEAR ENDED OCTOBER 2, 2004
Comment applicable to your overall filing
1. Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like. Some of our comments refer to
US
GAAP literature. If your accounting under UK GAAP differs from
your
accounting under US GAAP, please also show us the additional
disclosures that will be included in your US GAAP reconciliation
footnote. These revisions should be included in your future
filings
beginning to the extent practical with your report of Form 6-K
announcing results for the 26 weeks ending about April 2, 2005.
Item 3. Key Information
Selected Financial Data, page 2
2. Based on your response to our comment 2, we would not object to
your suggestion regarding only including the ADS information in
the
Selected Financial Data.
Financial Statements
2. Accounting policies, page F-8
3. We have read your response to our comments 11 and 12. Please
expand your disclosure to specify which line item within operating
profit/(loss) your licensing costs and shipping, handling,
inspection
and distribution costs incurred by you are included. If you
currently exclude these shipping related costs from food equipment
costs, please disclose:
* in a footnote the line items that these excluded costs are
included
in and the amounts included in each line item for each period
presented, and
* in MD&A that your gross margins may not be comparable to those
of
other entities, since some entities include these costs in cost of
sales and others like you exclude these costs from gross margin,
including them instead in a line item, such as corporate costs.
Refer to paragraph 6 of EITF 00-10.
28. Supplementary Information for U.S. Investors
Consolidated Statements of Cash Flows, page F-54
4. We have read your response to our comment 17. It appears as
though the detail relating to operating activities was excluded.
Ensure this information is included in your disclosure in future
filings.
* * * *
As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information. Detailed
response
letters greatly facilitate our review. Please file your response
letter on EDGAR. Please understand that we may have additional
comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please
direct them to Meagan Caldwell, Staff Accountant, at (202) 824-
5578
or, in her absence, Nathan Cheney, Assistant Chief Accountant, at
(202)942-1804.
Sincerely,
John Hartz
Senior Assistant Chief
Accountant
??
??
??
??
Mr. David S. McCulloch
April 18, 2005
Page 1 of 3
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510
DIVISION OF
CORPORATION FINANCE
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