SEC Comment Letter for BED BATH & BEYOND, INC. (NXH, BBBYW) (CIK 0001130713) (NXH) — Jan 11, 2011
BED BATH & BEYOND, INC. (NXH, BBBYW) (CIK 0001130713)
Date: Jan. 11, 2011 · CIK: 0001130713 · Accession: 0000000000-11-002216
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-49799
Referenced dates: December 13, 2010, December 28, 2010
Letter
Re: Overstock.com, Inc. Form 10-Q for the Quarterly Period Ended September 30, 2010 Filed October 29, 2010 File No. 000-49799 Dear Mr. Byrne: We have reviewed your supplemental res ponse letter dated December 28, 2010 and have the following comment. Form 10-Q for the quarterly period ended September 30, 2010
January 11, 2011 By Facsimile and U.S. Mail
Mr. Stephen J. Chesnut Senior Vice President, Finance and Risk Management Overstock.com, Inc. 6350 South 3000 East Salt Lake City, UT 84121
2. Accounting Policies, page 7 Sales returns allowance, page 12 1. We read your response to comments one and two to our letter dated December 13, 2010. Please address the following: • Refer to number 28 and Exhibit 1 of your response letter da ted July 9, 2010. Your Exhibit 1 is entitled, “Estimate of Sales Returns compared to Actual Sales Returns Experience.” Please provide to us a roll-forward of this schedule throughout each quarterly period in fisc al 2010. Further, please revise the schedule to add the first quarter of fiscal 2007. • Please supplement this schedule with an analysis which shows the following: 1) the calculation of the difference between your sales returns estimate recorded at the end of the current qu arter compared to your actual experience in the subsequent quarter; and 2) on a cumulati ve quarterly basis, any over or under accrual in your quarterly allowance for sales returns beginning in fiscal 2007 throughout the end of fiscal 2010. For example, the cumulative quarterly difference would be calculated every quarter by taking the current quarter’s difference between the estimate recorded a nd subsequent quarter’s actual returns and adding the prior cumulative quarterly differences between the estimated and actual sales returns. Lastl y, explain to us the underlyi ng reasons for any material over or under accruals in your allowance for sales returns observed on a
Mr. Stephen J. Chesnut Overstock.com, Inc. January 11, 2011 Page 2
cumulative quarterly basis. If material differences are noted in any quarterly or fiscal year end period, then explain to us how you concluded your allowance for sales returns was reasonable. • We note “actual returns pro cessed in subsequent quarter s” provided in Exhibit 1 of your December 28, 2010 response reflects returns received in month four or thereafter of the sale. Please confirm that the actual returns processed in subsequent quarters relate to the sales for the quarter i ndicated in your exhibit. Further, please supplement your table to in clude a table showing the actual returns processed each month including the month of the sale.
As appropriate, please amend your filing and respond to this comment within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendments to expedite our review. Please furnish a cover letter with your amendments that keys your responses to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please submit your cover lett er over EDGAR. Please unde rstand that we may have additional comments after reviewing your am endments and responses to our comment. You may contact Robert Babula, Staff Accountant, at 202-5 51-3339 or Donna Di Silvio, Staff Accountant, at 202-551-3202 if you have ques tions regarding this co mment on the financial statements and related matters. Please cont act me at 202-551-3720 with any other questions.
Sincerely,
Andrew Mew Accounting Branch Chief
Show Raw Text
January 11, 2011
By Facsimile and U.S. Mail
Mr. Stephen J. Chesnut Senior Vice President, Finance and Risk Management Overstock.com, Inc. 6350 South 3000 East Salt Lake City, UT 84121
Re: Overstock.com, Inc. Form 10-Q for the Quarterly Period Ended September 30, 2010
Filed October 29, 2010 File No. 000-49799
Dear Mr. Byrne:
We have reviewed your supplemental res ponse letter dated December 28, 2010 and have
the following comment. Form 10-Q for the quarterly period ended September 30, 2010
2. Accounting Policies, page 7
Sales returns allowance, page 12
1. We read your response to comments one and two to our letter dated December 13, 2010.
Please address the following:
• Refer to number 28 and Exhibit 1 of your response letter da ted July 9, 2010.
Your Exhibit 1 is entitled, “Estimate of Sales Returns compared to Actual Sales
Returns Experience.” Please provide to us a roll-forward of this schedule
throughout each quarterly period in fisc al 2010. Further, please revise the
schedule to add the first quarter of fiscal 2007.
• Please supplement this schedule with an analysis which shows the following: 1)
the calculation of the difference between your sales returns estimate recorded at
the end of the current qu arter compared to your actual experience in the
subsequent quarter; and 2) on a cumulati ve quarterly basis, any over or under
accrual in your quarterly allowance for sales returns beginning in fiscal 2007
throughout the end of fiscal 2010. For example, the cumulative quarterly difference would be calculated every quarter by taking the current quarter’s
difference between the estimate recorded a nd subsequent quarter’s actual returns
and adding the prior cumulative quarterly differences between the estimated and
actual sales returns. Lastl y, explain to us the underlyi ng reasons for any material
over or under accruals in your allowance for sales returns observed on a
Mr. Stephen J. Chesnut Overstock.com, Inc.
January 11, 2011 Page 2
cumulative quarterly basis. If material differences are noted in any quarterly or
fiscal year end period, then explain to us how you concluded your allowance for
sales returns was reasonable.
• We note “actual returns pro cessed in subsequent quarter s” provided in Exhibit 1
of your December 28, 2010 response reflects returns received in month four or
thereafter of the sale. Please confirm that the actual returns processed in
subsequent quarters relate to the sales for the quarter i ndicated in your exhibit.
Further, please supplement your table to in clude a table showing the actual returns
processed each month including the month of the sale.
As appropriate, please amend your filing and respond to this comment within 10 business
days or tell us when you will provide us with a response. You may wish to provide us with
marked copies of the amendments to expedite our review. Please furnish a cover letter with your
amendments that keys your responses to our comment and provides any requested information.
Detailed cover letters greatly facilitate our review.
Please submit your cover lett er over EDGAR. Please unde rstand that we may have
additional comments after reviewing your am endments and responses to our comment.
You may contact Robert Babula, Staff Accountant, at 202-5 51-3339 or Donna Di Silvio,
Staff Accountant, at 202-551-3202 if you have ques tions regarding this co mment on the financial
statements and related matters. Please cont act me at 202-551-3720 with any other questions.
Sincerely,
Andrew Mew Accounting Branch Chief