SEC Comment Letter for AAC Group Holding Corp. (CIK 0001311835) — Aug 31, 2005
AAC Group Holding Corp. (CIK 0001311835)
Date: Aug. 31, 2005 · CIK: 0001311835 · Accession: 0000000000-05-045367
AI Filing Summary & Sentiment
File numbers found in text: 333-121479
Referenced dates: June 22, 2005
Letter
Mail Stop 3561 August 19, 2005 David G. Fiore President and Chief Executive Officer AAC Group Holding Corp. 7211 Circle S Road Austin, Texas 78745
Re: AAC Group Holding Corp. Amendment No. 4 to Registration Statement on Form S-4 Filed June 7, 2005 Form 8-K Filed July 22, 2005 File No. 333-121479
Dear Mr. Fiore:
We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Consolidated Financial Statements and Notes to Consolidated Financial Statements
Note 17: Business Segments (Restated), page F-36
1. In your response to comment 1 in our letter dated June 22, 2005, you state that the operating segments of On Campus Class Rings and Retail Class Rings have been aggregated into one reportable segment. Please disclose that operating segments have been aggregated in accordance with paragraph 26.a. of FAS 131.
Form 8-K filed July 22, 2005
2. It does not appear that you have included all of the information required by Item 5.02 of Form 8-K. Please advise or revise.
*****
As appropriate, please amend your filings in response to these comments. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comment
You may contact Dave Irving at (202) 551-3321 or Mike Moran, Accounting Branch Chief, at (202) 551-3841 if you have questions regarding comments on the financial statements and related matters. Please direct any other questions to Howard M. Baik at (202) 551- or to Ellie Quarles, Special Counsel, at (202) 551-3238.
Sincerely,
H. Christopher Owings
Assistant Director
Show Raw Text
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Mail Stop 3561
August 19, 2005
David G. Fiore
President and Chief Executive Officer
AAC Group Holding Corp.
7211 Circle S Road
Austin, Texas 78745
Re: AAC Group Holding Corp.
Amendment No. 4 to Registration Statement on Form S-4
Filed June 7, 2005
Form 8-K
Filed July 22, 2005
File No. 333-121479
Dear Mr. Fiore:
We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure. After
reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Consolidated Financial Statements and Notes to Consolidated
Financial
Statements
Note 17: Business Segments (Restated), page F-36
1. In your response to comment 1 in our letter dated June 22,
2005,
you state that the operating segments of On Campus Class Rings and
Retail Class Rings have been aggregated into one reportable
segment.
Please disclose that operating segments have been aggregated in
accordance with paragraph 26.a. of FAS 131.
Form 8-K filed July 22, 2005
2. It does not appear that you have included all of the
information
required by Item 5.02 of Form 8-K. Please advise or revise.
*****
As appropriate, please amend your filings in response to
these
comments. You may wish to provide us with marked copies of the
amendment to expedite our review. Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information. Detailed letters greatly facilitate
our
review. Please understand that we may have additional comments
after
reviewing your amendment and responses to our comment
You may contact Dave Irving at (202) 551-3321 or Mike Moran,
Accounting Branch Chief, at (202) 551-3841 if you have questions
regarding comments on the financial statements and related
matters.
Please direct any other questions to Howard M. Baik at (202) 551-
3317
or to Ellie Quarles, Special Counsel, at (202) 551-3238.
Sincerely,
H. Christopher Owings
Assistant Director
cc (via fax): Joel F. Freedman, Esq.
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David G. Fiore
AAC Group Holding Corp.
August 19, 2005
Page 2
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