SEC Comment Letter for CIMPRESS plc (CMPR) (CIK 0001262976) (CMPR) — Jun 15, 2009
CIMPRESS plc (CMPR) (CIK 0001262976)
Date: June 15, 2009 · CIK: 0001262976 · Accession: 0000000000-09-031686
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-51539
Referenced dates: March 3, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3561 May 19, 2009 Mr. Robert S. Kean Chief Executive Officer VistaPrint Limited 22 Victoria Street Hamilton, HM 12 Bermuda Re: VistaPrint Limited Form 10-K and 10-K/A for fiscal year ended June 30, 2008 Filed August 29, 2008 (10-K/A filed October 8, 2008) File No. 000-51539
Dear Mr. Kean: We have reviewed your responses to the comments in our letter dated March 3, 2009 and have the following additional comments. Please respond to confirm that such comments will be complied with, or, if certain of the comments are deemed inappropr iate, advise the staff of your reason. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond w ithin ten (10) business days. General – Form 10-K
1. We note your response to our comment 1 and reissue in part. Please amend your Form 10-K/A to file CEO and CFO certifications that include Paragraph 3 of Item 601(b)(31) of Regulation S- K. Please refer to SEC Release No. 33- 8124.
2. In addition, in light of your amendment to Form 10-K to correct a misstated number in your MD&A, please set forth in reasonable detail the basis for management’s conclusion that your disc losure controls a nd procedures were nonetheless effective as of the end of the period covered by your 10-K.
Mr. Robert S. Kean VistaPrint Limited May 19, 2009 Page 2
* * * * *
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing. If you have any questions regarding these comments, you may contact Chanda DeLong at (202) 551-3490. If you need further assistance, you may contact me at (202) 551-3314. R e g a r d s , D a n i e l M o r r i s A t t o r n e y - A d v i s o r cc: Mr. Tom Ward via facsimile (617-526-5000)
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3561 May 19, 2009 Mr. Robert S. Kean Chief Executive Officer VistaPrint Limited 22 Victoria Street Hamilton, HM 12 Bermuda Re: VistaPrint Limited Form 10-K and 10-K/A for fiscal year ended June 30, 2008 Filed August 29, 2008 (10-K/A filed October 8, 2008) File No. 000-51539 Dear Mr. Kean: We have reviewed your responses to the comments in our letter dated March 3, 2009 and have the following additional comments. Please respond to confirm that such comments will be complied with, or, if certain of the comments are deemed inappropr iate, advise the staff of your reason. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond w ithin ten (10) business days. General – Form 10-K 1. We note your response to our comment 1 and reissue in part. Please amend your Form 10-K/A to file CEO and CFO certifications that include Paragraph 3 of Item 601(b)(31) of Regulation S- K. Please refer to SEC Release No. 33- 8124. 2. In addition, in light of your amendment to Form 10-K to correct a misstated number in your MD&A, please set forth in reasonable detail the basis for management’s conclusion that your disc losure controls a nd procedures were nonetheless effective as of the end of the period covered by your 10-K. Mr. Robert S. Kean VistaPrint Limited May 19, 2009 Page 2 * * * * * We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing. If you have any questions regarding these comments, you may contact Chanda DeLong at (202) 551-3490. If you need further assistance, you may contact me at (202) 551-3314. R e g a r d s , D a n i e l M o r r i s A t t o r n e y - A d v i s o r cc: Mr. Tom Ward via facsimile (617-526-5000)