SEC Comment Letter for Atkore Inc. (ATKR) (CIK 0001666138) (ATKR) — May 26, 2016
Atkore Inc. (ATKR) (CIK 0001666138)
Date: May 26, 2016 · CIK: 0001666138 · Accession: 0000000000-16-078217
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-209940
Letter
Mail Stop 3030 May 26, 2016 Via E -Mail John P. Williamson Chief Executive Officer Atkore International Group Inc. 16100 South Lathrop Avenue Harvey, Illinois 60426
Re: Atkore International Group Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed May 19, 2016 File No. 333-209940
Dear Mr. Williamson :
We have reviewed your amended registration statement and 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 by amending your registration statement and providing the requested information . If you do not believe our comments apply t o 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 registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise , our references to prior comments are to comments in our May 18, 2016 letter .
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
1. Please expand your response to prior comment 1 to tell us whether any of the industry or end markets that you serve disproportionate ly impact your business relative to other industries or end markets.
John P. Williamson Atkore International Group Inc. May 26, 2016 Page 2
Certain Relationships and Related Party Transactions, page 127
2. We note your response to prior comment 6. Please disclose the dispute involving this related -party transaction. You may contact Kristin Lochhead at (202) 551 -3664 or Gary Todd, Senior Accountant, at (202) 551 -3605 if you have questions regardi ng comments on the financial statements and related matters. Please contact Laurie Abbott at (202) 551 -8071 or me at (202) 551 -3617 with any other questions.
Sincerely,
/s/ Russell Mancuso
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Mail Stop 3030 May 26, 2016 Via E -Mail John P. Williamson Chief Executive Officer Atkore International Group Inc. 16100 South Lathrop Avenue Harvey, Illinois 60426 Re: Atkore International Group Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed May 19, 2016 File No. 333-209940 Dear Mr. Williamson : We have reviewed your amended registration statement and 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 by amending your registration statement and providing the requested information . If you do not believe our comments apply t o 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 registration statement and the information you provide in response to these comments, we may have additional comments. Unless we note otherwise , our references to prior comments are to comments in our May 18, 2016 letter . Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 47 1. Please expand your response to prior comment 1 to tell us whether any of the industry or end markets that you serve disproportionate ly impact your business relative to other industries or end markets. John P. Williamson Atkore International Group Inc. May 26, 2016 Page 2 Certain Relationships and Related Party Transactions, page 127 2. We note your response to prior comment 6. Please disclose the dispute involving this related -party transaction. You may contact Kristin Lochhead at (202) 551 -3664 or Gary Todd, Senior Accountant, at (202) 551 -3605 if you have questions regardi ng comments on the financial statements and related matters. Please contact Laurie Abbott at (202) 551 -8071 or me at (202) 551 -3617 with any other questions. Sincerely, /s/ Russell Mancuso Russell Mancuso Branch Chief Office of Electronics and Machinery cc: Paul M. Rodel, Esq. Debevoise & Plimpton LLP