SEC Comment Letter for CIMPRESS plc (CMPR) (CIK 0001262976) (CMPR) — Mar 13, 2015
CIMPRESS plc (CMPR) (CIK 0001262976)
Date: March 13, 2015 · CIK: 0001262976 · Accession: 0000000000-15-014955
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-51539
Letter
March 13, 2015 Ernst J. Teunissen Chief Financial Officer Cimpress N.V. Hudsonweg 8 5928 LW Venlo The Netherlands
Re: Cimpress N.V. Form 10-K for the Fiscal Year Ended June 30, 2014 Filed August 15, 2014 File No. 000-51539
Dear Mr. Teunissen:
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 busine ss days by providing the requested information or advis e 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 re sponse.
After reviewing your response to these comments, we may have additional comments
Form 10 -K for the Fiscal Year Ended June 30, 2014
Financial Statements
Notes to Consolidated Financial Statements
16. Noncontrolling Interest, page 81
1. We note that you have included the 49% noncontrolling interest of Plaza Create Co. as temporary equity in your consolidated balance sheet due to certain default provisions contained in the agreement. In this regard, please revise to disclose, in more detail, the nature of such default provisions and clearly explain why such provisions require the temporary equity classification in the balance sheet according to ASR 268 and ASC 480 - 10-S99-3A.
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 the information the Securities Exchange Act of 1934
Ernst J. Teunissen Cimpress N.V. March 13, 2015 Page 2
and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a com pany’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 as sert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
You may contact Heather Clark at 202 -551-3624 or Andrew Mew at 202-551-3377 if you have questions regarding comments on the financial s tatements and related matters. Please contact me at 202 -551-3379 with any other questions.
Sincerely,
/s/ Melissa Raminpour
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March 13, 2015 Ernst J. Teunissen Chief Financial Officer Cimpress N.V. Hudsonweg 8 5928 LW Venlo The Netherlands Re: Cimpress N.V. Form 10-K for the Fiscal Year Ended June 30, 2014 Filed August 15, 2014 File No. 000-51539 Dear Mr. Teunissen: 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 busine ss days by providing the requested information or advis e 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 re sponse. After reviewing your response to these comments, we may have additional comments Form 10 -K for the Fiscal Year Ended June 30, 2014 Financial Statements Notes to Consolidated Financial Statements 16. Noncontrolling Interest, page 81 1. We note that you have included the 49% noncontrolling interest of Plaza Create Co. as temporary equity in your consolidated balance sheet due to certain default provisions contained in the agreement. In this regard, please revise to disclose, in more detail, the nature of such default provisions and clearly explain why such provisions require the temporary equity classification in the balance sheet according to ASR 268 and ASC 480 - 10-S99-3A. 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 the information the Securities Exchange Act of 1934 Ernst J. Teunissen Cimpress N.V. March 13, 2015 Page 2 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a com pany’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 as sert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. You may contact Heather Clark at 202 -551-3624 or Andrew Mew at 202-551-3377 if you have questions regarding comments on the financial s tatements and related matters. Please contact me at 202 -551-3379 with any other questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief