SEC Comment Letter for Designer Brands Inc. (DBI) (CIK 0001319947) (DBI) — Jun 13, 2005
Designer Brands Inc. (DBI) (CIK 0001319947)
Date: June 13, 2005 · CIK: 0001319947 · Accession: 0000000000-05-029309
AI Filing Summary & Sentiment
File numbers found in text: 333-123289
Letter
Mail Stop 03-08 June 10, 2005 Julia A. Davis General Counsel DSW Inc. 3241 Westerville Road Columbus, Ohio 43224
Re: DSW Inc. Amendment No. 2 to Form S-1 Filed June 7, 2005 File No. 333-123289
Dear Ms. Davis:
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 any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
About this Prospectus
1. We note that you believe the information obtained from NPD Fashionworld is reliable, but that you "have not independently verified and cannot guarantee the accuracy or completeness of the information." Please note that you are responsible for the entire content of the registration statement and cannot include language that can be interpreted as a disclaimer of the information contained in the filing. Please revise.
Certain Relationships and Related Party Transaction Notes, Credit Agreements and Guarantees, page 87
The Value City Senior Subordinated Convertible Loan Facility, page
2. Please tell us what consideration you gave to the requirements of EITF 96-18 with respect to the warrants to be issued to SSC and Cerberus.
* * * * *
As appropriate, please amend your registration statement 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 cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
You may contact Ta Tanisha Henderson at (202) 551-3322 or George Ohsiek, Accounting Branch Chief, at (202) 551-3843 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
Show Raw Text
<DOCUMENT>
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<TEXT>
Mail Stop 03-08
June 10, 2005
Julia A. Davis
General Counsel
DSW Inc.
3241 Westerville Road
Columbus, Ohio 43224
Re: DSW Inc.
Amendment No. 2 to Form S-1
Filed June 7, 2005
File No. 333-123289
Dear Ms. Davis:
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 any other aspect of
our
review. Feel free to call us at the telephone numbers listed at
the
end of this letter.
About this Prospectus
1. We note that you believe the information obtained from NPD
Fashionworld is reliable, but that you "have not independently
verified and cannot guarantee the accuracy or completeness of the
information." Please note that you are responsible for the entire
content of the registration statement and cannot include language
that
can be interpreted as a disclaimer of the information contained in
the
filing. Please revise.
Certain Relationships and Related Party Transaction
Notes, Credit Agreements and Guarantees, page 87
The Value City Senior Subordinated Convertible Loan Facility, page
88
2. Please tell us what consideration you gave to the requirements
of
EITF 96-18 with respect to the warrants to be issued to SSC and
Cerberus.
* * * * *
As appropriate, please amend your registration statement 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 cover
letters greatly facilitate our review. Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.
You may contact Ta Tanisha Henderson at (202) 551-3322 or
George
Ohsiek, Accounting Branch Chief, at (202) 551-3843 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: Robert M. Chilstrom, Esq.
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Julia A. Davis
DSW Inc.
June 10, 2005
Page 1
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