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SEC Comment Letter for Canada Goose Holdings Inc. (GOOS) (CIK 0001690511) (GOOS) — Feb 5, 2020

Canada Goose Holdings Inc. (GOOS) (CIK 0001690511)
Date: Feb. 5, 2020 · CIK: 0001690511 · Accession: 0000000000-20-001144

AI Filing Summary & Sentiment

File numbers found in text: 001-38027

Date
February 5, 2020
Author
Not clearly detected
Form
UPLOAD
Company
Canada Goose Holdings Inc. (GOOS) (CIK 0001690511)

Letter

February 5, 2020 Jonathan Sinclair Chief Financial Officer Canada Goose Holdings Inc. 250 Bowie Ave Toronto, Ontario, Canada M6E 4Y2 Re:Canada Goose Holdings Inc. Form 20-F for the Fiscal Year Ended March 31, 2019 Filed May 29, 2019 File No. 001-38027 Dear Mr. Sinclair: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 20-F for the Fiscal Year Ended March 31, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 50 1.We note that your comparative discussions for all respective periods of your income statement line items identify multiple variables as the reasons for the period to period changes in your operating results; however, you do not quantify the impact of each of these variables. Please also note that prefacing a reference to the source or sources of changes with the word "primarily" obscures the ability of the reader to identify the material sources of the change. In addition, where a material change is attributed to two or more factors, including any offsetting factors, the contribution of each identified factor should be described in quantified terms. Please revise to quantify the impact of each material factor that you discuss to provide your readers with better insight into the underlying reasons behind the changes in your results. Refer to Item 5 of Form 20-F and Section III.D of SEC Release No. 33-6835.

FirstName LastNameJonathan Sinclair Comapany NameCanada Goose Holdings Inc. February 5, 2020 Page 2 FirstName LastName Jonathan Sinclair Canada Goose Holdings Inc. February 5, 2020 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Melissa Gilmore at (202) 551-3777 or Jean Yu at (202) 551-3305 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing

Show Raw Text
February 5, 2020
Jonathan Sinclair
Chief Financial Officer
Canada Goose Holdings Inc.
250 Bowie Ave
Toronto, Ontario, Canada M6E 4Y2
Re:Canada Goose Holdings Inc.
Form 20-F for the Fiscal Year Ended March 31, 2019
Filed May 29, 2019
File No. 001-38027
Dear Mr. Sinclair:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  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 comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended March 31, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 50
1.We note that your comparative discussions for all respective periods of your income
statement line items identify multiple variables as the reasons for the period to period
changes in your operating results; however, you do not quantify the impact of each of
these variables. Please also note that prefacing a reference to the source or sources of
changes with the word "primarily" obscures the ability of the reader to identify the
material sources of the change. In addition, where a material change is attributed to two or
more factors, including any offsetting factors, the contribution of each identified factor
should be described in quantified terms. Please revise to quantify the impact of each
material factor that you discuss to provide your readers with better insight into the
underlying reasons behind the changes in your results. Refer to Item 5 of Form 20-F and
Section III.D of SEC Release No. 33-6835.

 FirstName LastNameJonathan Sinclair
 Comapany NameCanada Goose Holdings Inc.
 February 5, 2020 Page 2
 FirstName LastName
Jonathan Sinclair
Canada Goose Holdings Inc.
February 5, 2020
Page 2
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Melissa Gilmore at (202) 551-3777 or Jean Yu at (202) 551-3305 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing