SEC Company Response from Canada Goose Holdings Inc. (GOOS) (CIK 0001690511) (GOOS) — Feb 11, 2020
Canada Goose Holdings Inc. (GOOS) (CIK 0001690511)
Date: Feb. 11, 2020 · CIK: 0001690511 · Accession: 0001193125-20-031314
AI Filing Summary & Sentiment
File numbers found in text: 001-38027
Letter
ROPES & GRAY LLP
1211 AVENUE OF THE AMERICAS
NEW YORK, NY 10036-8704
WWW.ROPESGRAY.COM
February 11, 2020
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attention:
Melissa Gilmore
Jean Yu
Re:
Canada Goose Holdings Inc.
Form 20-F for the Fiscal Year Ended March 31, 2019
Filed May 29, 2019
File No. 001-38027
Ladies and Gentlemen:
On behalf of Canada Goose Holdings Inc. (the “Company”), we submit via EDGAR this letter in response to the written comments of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission, dated February 5, 2020 (the “Comment Letter”), with regard to the Company’s Form 20-F for the fiscal year ended March 31, 2019 (filed May 29, 2019). For the convenience of the Staff’s review, we have set forth the comments contained in the Comment Letter in italics followed by the responses of the Company.
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.
Securities and Exchange Commission
Division of Corporation Finance
February 11, 2020
Response:
The Company acknowledges the Staff’s comment and in future filings of the Annual Report on Form 20-F, the Company will quantify the impact of each material factor discussed as an underlying reason behind the period to period changes in the Company’s operating results.
***
We hope that the foregoing has been responsive to the Staff’s comments. If you have any questions or comments about this letter or need any further information, please call the undersigned at (212) 841-8857.
Very truly yours,
/s/ Rachel Phillips
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CORRESP 1 filename1.htm CORRESP ROPES & GRAY LLP 1211 AVENUE OF THE AMERICAS NEW YORK, NY 10036-8704 WWW.ROPESGRAY.COM February 11, 2020 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, D.C. 20549 Attention: Melissa Gilmore Jean Yu Re: Canada Goose Holdings Inc. Form 20-F for the Fiscal Year Ended March 31, 2019 Filed May 29, 2019 File No. 001-38027 Ladies and Gentlemen: On behalf of Canada Goose Holdings Inc. (the “Company”), we submit via EDGAR this letter in response to the written comments of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission, dated February 5, 2020 (the “Comment Letter”), with regard to the Company’s Form 20-F for the fiscal year ended March 31, 2019 (filed May 29, 2019). For the convenience of the Staff’s review, we have set forth the comments contained in the Comment Letter in italics followed by the responses of the Company. 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. Securities and Exchange Commission Division of Corporation Finance February 11, 2020 Response: The Company acknowledges the Staff’s comment and in future filings of the Annual Report on Form 20-F, the Company will quantify the impact of each material factor discussed as an underlying reason behind the period to period changes in the Company’s operating results. *** 2 We hope that the foregoing has been responsive to the Staff’s comments. If you have any questions or comments about this letter or need any further information, please call the undersigned at (212) 841-8857. Very truly yours, /s/ Rachel Phillips Rachel Phillips cc: David M. Forrest (Canada Goose Holdings Inc.)