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SEC Comment Letter for BRIGHT HORIZONS FAMILY SOLUTIONS INC. (BFAM) (CIK 0001437578) (BFAM) — Oct 21, 2014

BRIGHT HORIZONS FAMILY SOLUTIONS INC. (BFAM) (CIK 0001437578)
Date: Oct. 21, 2014 · CIK: 0001437578 · Accession: 0000000000-14-052352

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
October 21, 2014
Author
/s/Tia L. Jenkins
Form
UPLOAD
Company
BRIGHT HORIZONS FAMILY SOLUTIONS INC. (BFAM) (CIK 0001437578)

Letter

October 21, 2014 Via E -mail David Lissy Chief Executive Officer Bright Horizons Family Solutions, Inc. 200 Talcott Avenue South Watertown, MA 02472

Re: Bright Horizons Family Solutions, Inc . Form 10-K for the Year Ended December 31, 2013 Filed March 25, 2014 File No. 001 -35780

Dear Mr. Lissy :

We have reviewed your filing an d have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, 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 circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.

Form 10 -K for the Year Ended December 31, 2013

Exhibits 31.1 and 31.2

1. You include Management’s Report on Internal Control over Financial Reporting under Item 9A. However, y our Section 302 certifi cations do not appear to comply with Item 601(b)(31) of Regulation S -K, as follows :  The introductory portion of paragraph 4 does not include a reference to internal control over financial reporting (as defined in Exchange Act Rules 13a -15(f) and 15d-15(f)) , and  Paragraph 4(b) was not included. Please file an amendment to your Form 10 -K with updated certifications that follow the wording shown in Item 601(b)(31) of Regulation S -K.

David Lissy Bright Hori zons Family Solutions , Inc. October 21, 2014 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 the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the compa ny and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the co mpany 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.

You may contact Blaise Rhodes at (202) 551 -3774 or Rufus Decker, Branch Chief, at (202) 551 -3769 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
/s/Tia L. Jenkins

Show Raw Text
October 21, 2014

Via E -mail
David Lissy
Chief Executive  Officer
Bright Horizons Family Solutions, Inc.
200 Talcott Avenue South
Watertown, MA  02472

Re: Bright Horizons Family Solutions, Inc .
 Form 10-K for the Year Ended December 31, 2013
Filed March 25, 2014
File No. 001 -35780

Dear Mr. Lissy :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, 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 circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have  additional comments.

Form 10 -K for the Year Ended December 31, 2013

Exhibits 31.1 and 31.2

1. You include Management’s Report on Internal Control over Financial Reporting under
Item 9A.  However, y our Section 302 certifi cations do not appear to comply with Item
601(b)(31) of Regulation S -K, as follows :
 The introductory portion of paragraph 4 does not include a reference to internal
control over financial reporting (as defined in Exchange Act Rules 13a -15(f) and
15d-15(f)) , and
 Paragraph 4(b) was not included.
Please  file an amendment to your Form 10 -K with updated certifications that follow
the wording shown in Item 601(b)(31) of Regulation S -K.

David Lissy
Bright Hori zons Family Solutions , Inc.
October 21, 2014
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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the co mpany
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.

You may contact Blaise Rhodes  at (202) 551 -3774  or Rufus Decker,  Branch Chief,  at
(202) 551 -3769 if you have questions regarding comments on the financial statements and
related matters.

Sincerely,

 /s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining