SEC Comment Letter for Ulta Beauty, Inc. (ULTA) (CIK 0001403568) (ULTA) — Jan 20, 2011
Ulta Beauty, Inc. (ULTA) (CIK 0001403568)
Date: Jan. 20, 2011 · CIK: 0001403568 · Accession: 0000000000-11-004020
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 3, 2010, January 4, 2011
Letter
January 20, 2011 Carl Rubin Chief Executive Officer Ulta Salon, Cosmetics & Fragrance, Inc. 1000 Remington Blvd., Suite 120 Bolingbrook, Illinois 60440 Re: Ulta Salon, Cosmetics & Fragrance, Inc. Form 10-K for the fiscal year ended January 30, 2010 Filed March 31, 2010 Forms 10-Q for the periods ended May 1, 2010, July 31, 2010, and October 30, 2010 Filed June 3, 2010, September 2, 2010, and December 2, 2010, respectively Definitive Proxy Statement on Schedule 14A Filed May 7, 2010 File No. 1-33764
Dear Mr. Rubin: We have reviewed your supplemental response letter dated January 4, 2011 and have the following comments. Form 10-K for the fiscal year ended January 30, 2010
Item 15. Exhibits and Financia l Statement Schedules, page 46 2.Summary of significant acc ounting policies, page 55 1. We read your response to comment five of our letter dated December 3, 2010. We note you do not believe that separate disclosure of salon services revenue would be beneficial to the readers of your financial statements . We do not concur with your conclusion. Please revise your future disclosure or a dvise us in detail why the readers of your financial statements would not find disclosu re of the extent of services provided information useful or beneficial. Self-insurance, page 58
2. We read your response to comment 10 of our letter dated December 3, 2010. We believe the amounts charged to expense are signifi cant and that you shoul d include a tabular presentation of your reserve activity. Pleas e confirm to us that you will present this information in future filings.
Carl Rubin Ulta Salon, Cosmetics & Fragrance, Inc. January 20, 2011 Page 2
Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances please tell us why in your response.
Please submit your cover lett er over EDGAR. Please unde rstand that we may have additional comments after reviewing your amendments and responses to our comments. You may contact Robert Babul a, Staff Accountant, at ( 202) 551-3339 or in his absence Donna Di Silvio, Staff Accountant, at (202) 551-3202 if you have questions regarding comments on the financial statements and related matters. Pl ease contact Lilyanna Peyser, Staff Attorney, at (202) 551-3222 or me at (202) 551- 3377 with any other questions.
Sincerely,
Andrew Mew Accounting Branch Chief
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January 20, 2011 Carl Rubin Chief Executive Officer Ulta Salon, Cosmetics & Fragrance, Inc. 1000 Remington Blvd., Suite 120 Bolingbrook, Illinois 60440 Re: Ulta Salon, Cosmetics & Fragrance, Inc. Form 10-K for the fiscal year ended January 30, 2010 Filed March 31, 2010 Forms 10-Q for the periods ended May 1, 2010, July 31, 2010, and October 30, 2010 Filed June 3, 2010, September 2, 2010, and December 2, 2010, respectively Definitive Proxy Statement on Schedule 14A Filed May 7, 2010 File No. 1-33764 Dear Mr. Rubin: We have reviewed your supplemental response letter dated January 4, 2011 and have the following comments. Form 10-K for the fiscal year ended January 30, 2010 Item 15. Exhibits and Financia l Statement Schedules, page 46 2.Summary of significant acc ounting policies, page 55 1. We read your response to comment five of our letter dated December 3, 2010. We note you do not believe that separate disclosure of salon services revenue would be beneficial to the readers of your financial statements . We do not concur with your conclusion. Please revise your future disclosure or a dvise us in detail why the readers of your financial statements would not find disclosu re of the extent of services provided information useful or beneficial. Self-insurance, page 58 2. We read your response to comment 10 of our letter dated December 3, 2010. We believe the amounts charged to expense are signifi cant and that you shoul d include a tabular presentation of your reserve activity. Pleas e confirm to us that you will present this information in future filings. Carl Rubin Ulta Salon, Cosmetics & Fragrance, Inc. January 20, 2011 Page 2 Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances please tell us why in your response. Please submit your cover lett er over EDGAR. Please unde rstand that we may have additional comments after reviewing your amendments and responses to our comments. You may contact Robert Babul a, Staff Accountant, at ( 202) 551-3339 or in his absence Donna Di Silvio, Staff Accountant, at (202) 551-3202 if you have questions regarding comments on the financial statements and related matters. Pl ease contact Lilyanna Peyser, Staff Attorney, at (202) 551-3222 or me at (202) 551- 3377 with any other questions. Sincerely, Andrew Mew Accounting Branch Chief