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Showing: SCANSOURCE, INC.
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SEC Comment Letters
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Letter Text
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): 000-26926  ·  Started: 2026-05-04  ·  Last active: 2026-05-04
Awaiting Response 0 company response(s) High
UL SEC wrote to company 2026-05-04
SCANSOURCE, INC.
File Nos in letter: 000-26926
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): 000-26926  ·  Started: 2026-03-13  ·  Last active: 2026-04-23
Response Received 2 company response(s) High - file number match
UL SEC wrote to company 2026-03-13
SCANSOURCE, INC.
File Nos in letter: 000-26926
↓
CR Company responded 2026-04-13
SCANSOURCE, INC.
File Nos in letter: 000-26926
References: March 13, 2026
↓
CR Company responded 2026-04-23
SCANSOURCE, INC.
File Nos in letter: 000-26926
References: March 13, 2026
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2022-04-28  ·  Last active: 2022-04-28
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2022-04-28
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2022-04-28
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2022-03-28  ·  Last active: 2022-04-26
Response Received 1 company response(s) Medium - date proximity
UL SEC wrote to company 2022-03-28
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2022-03-28
Generating summary...
↓
CR Company responded 2022-04-26
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2022-04-26
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2020-04-27  ·  Last active: 2020-04-27
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2020-04-27
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2020-04-27
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2020-04-09  ·  Last active: 2020-04-23
Response Received 1 company response(s) Medium - date proximity
UL SEC wrote to company 2020-04-09
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2020-04-09
Generating summary...
↓
CR Company responded 2020-04-23
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2020-04-23
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2016-05-02  ·  Last active: 2016-05-02
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2016-05-02
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2016-05-02
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2016-04-22  ·  Last active: 2016-04-22
Orphan - no UPLOAD in window 1 company response(s) Low - unmatched response
CR Company responded 2016-04-22
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2016-04-22
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2016-01-14  ·  Last active: 2016-02-26
Response Received 2 company response(s) Medium - date proximity
UL SEC wrote to company 2016-01-14
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2016-01-14
Generating summary...
↓
CR Company responded 2016-01-22
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2016-01-22
Generating summary...
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CR Company responded 2016-02-26
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2016-02-26
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2011-06-14  ·  Last active: 2011-06-14
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2011-06-14
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2011-06-14
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2011-03-18  ·  Last active: 2011-04-14
Response Received 2 company response(s) Medium - date proximity
UL SEC wrote to company 2011-03-18
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2011-03-18
Generating summary...
↓
CR Company responded 2011-03-29
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2011-03-29
Generating summary...
↓
CR Company responded 2011-04-14
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2011-04-14
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2009-08-03  ·  Last active: 2009-08-03
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2009-08-03
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2009-08-03
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2009-07-10  ·  Last active: 2009-07-10
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2009-07-10
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2009-07-10
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2009-05-29  ·  Last active: 2009-06-25
Response Received 1 company response(s) Medium - date proximity
UL SEC wrote to company 2009-05-29
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2009-05-29
Generating summary...
↓
CR Company responded 2009-06-25
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2009-06-25
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2009-05-04  ·  Last active: 2009-05-28
Response Received 2 company response(s) Medium - date proximity
UL SEC wrote to company 2009-05-04
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2009-05-04
Generating summary...
↓
CR Company responded 2009-05-08
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2009-05-08
Generating summary...
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CR Company responded 2009-05-28
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2009-05-28
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2009-04-03  ·  Last active: 2009-04-21
Response Received 1 company response(s) Medium - date proximity
UL SEC wrote to company 2009-04-03
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2009-04-03
Generating summary...
↓
CR Company responded 2009-04-21
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2009-04-21
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2007-05-31  ·  Last active: 2007-05-31
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2007-05-31
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2007-05-31
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2007-05-10  ·  Last active: 2007-05-10
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2007-05-10
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2007-05-10
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2007-03-21  ·  Last active: 2007-05-03
Response Received 1 company response(s) Medium - date proximity
UL SEC wrote to company 2007-03-21
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2007-03-21
Generating summary...
↓
CR Company responded 2007-05-03
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2007-05-03
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2007-01-20  ·  Last active: 2007-02-14
Response Received 2 company response(s) Medium - date proximity
UL SEC wrote to company 2007-01-20
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2007-01-20
Generating summary...
↓
CR Company responded 2007-01-30
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2007-01-30
Generating summary...
↓
CR Company responded 2007-02-14
SCANSOURCE, INC.
Filing - Correspondence from SCANSOURCE, INC.
CORRESP · 2007-02-14
Generating summary...
SCANSOURCE, INC.
CIK: 0000918965  ·  File(s): N/A  ·  Started: 2004-12-05  ·  Last active: 2004-12-05
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2004-12-05
SCANSOURCE, INC.
Filing - SEC Comment Letter to SCANSOURCE, INC.
UPLOAD · 2004-12-05
Generating summary...
DateTypeCompanyLocationFile NoLink
2026-05-04 SEC Comment Letter SCANSOURCE, INC. N/A 000-26926 Read Filing View
2026-04-23 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2026-04-13 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2026-03-13 SEC Comment Letter SCANSOURCE, INC. N/A 000-26926 Read Filing View
2022-04-28 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2022-04-26 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2022-03-28 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2020-04-27 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2020-04-23 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2020-04-09 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2016-05-02 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2016-04-22 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2016-02-26 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2016-01-22 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2016-01-14 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2011-06-14 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2011-04-14 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2011-03-29 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2011-03-18 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-08-03 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-07-10 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-06-25 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2009-05-29 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-05-28 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2009-05-08 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2009-05-04 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-04-21 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2009-04-03 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2007-05-31 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2007-05-10 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2007-05-03 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2007-03-21 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2007-02-14 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2007-01-30 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2007-01-20 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2004-12-05 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2026-05-04 SEC Comment Letter SCANSOURCE, INC. N/A 000-26926 Read Filing View
2026-03-13 SEC Comment Letter SCANSOURCE, INC. N/A 000-26926 Read Filing View
2022-04-28 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2022-03-28 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2020-04-27 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2020-04-09 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2016-05-02 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2016-01-14 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2011-06-14 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2011-03-18 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-08-03 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-07-10 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-05-29 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-05-04 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2009-04-03 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2007-05-31 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2007-05-10 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2007-03-21 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2007-01-20 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
2004-12-05 SEC Comment Letter SCANSOURCE, INC. N/A N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2026-04-23 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2026-04-13 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2022-04-26 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2020-04-23 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2016-04-22 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2016-02-26 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2016-01-22 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2011-04-14 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2011-03-29 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2009-06-25 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2009-05-28 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2009-05-08 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2009-04-21 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2007-05-03 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2007-02-14 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2007-01-30 Company Response SCANSOURCE, INC. N/A N/A Read Filing View
2026-05-04 - UPLOAD - SCANSOURCE, INC. File: 000-26926
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 4, 2026

Steve Jones
Senior Executive Vice President and Chief Financial Officer
ScanSource Inc.
6 Logue Court
Greenville , South Carolina 29615

 Re: ScanSource Inc.
 Form 10-K for the Fiscal Year Ended June 30, 2025
 Filed August 21, 2025
 File No. 000-26926
Dear Steve Jones:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>
2026-04-23 - CORRESP - SCANSOURCE, INC.
Read Filing Source Filing Referenced dates: March 13, 2026
CORRESP
 1
 filename1.htm

 Document April 23, 2026 Via EDGAR Submission Office of Trade & Services Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: ScanSource, Inc. Form 10-K for the Fiscal Year Ended June 30, 2025 Filed August 21, 2025 File No. 000-26926 Ladies and Gentlemen: On behalf of ScanSource, Inc. (the “Company”), we respectfully submit the following responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) contained in its letter dated March 13, 2026 regarding the Company’s Form 10-K for the fiscal year ended June 30, 2025. For ease of reference, the Staff’s comments are restated below in italics, followed by the Company’s responses. Comment 1 Here you state “Incentives received from suppliers for specifically identified incremental market development funds are recorded as adjustments to net sales.” However, on page 35, you state “Incentives received from suppliers for specifically identified incremental market development funds are recorded as adjustments to selling, general and administrative expenses.” Please advise. Response The Company acknowledges the Staff’s comment and advises that the disclosure on page 53 of the Form 10-K, which states that incentives received from suppliers for specifically identified incremental market development funds are recorded as adjustments to net sales, is incorrect. The disclosure on page 35 correctly reflects the Company’s accounting policy, which has been applied consistently. Specifically, the Company records incentives received from suppliers for April 23, 2026 Page 2 specifically identified incremental market development funds as a reduction of selling, general and administrative expenses to the extent such incentives reimburse qualifying marketing costs incurred by the Company. Any amounts received in excess of such costs are recorded as a reduction of cost of goods sold. The Company does not record such incentives as a reduction of net sales. This accounting treatment is consistent with the guidance in ASC 705-20 and ASC 606-10 regarding consideration received from vendors. The Company will revise its significant accounting policy disclosures in future filings to clearly and consistently describe this accounting treatment and to remove references indicating that such incentives are recorded as adjustments to net sales. The revised disclosure will be substantially similar to the following: “Incentives received from suppliers for specifically identified incremental market development funds are recorded as a reduction of selling, general and administrative expenses to the extent they reimburse qualifying marketing costs incurred by the Company. Any amounts received in excess of such costs are recorded as a reduction of cost of goods sold.” Comment 2 Please tell us how your disclosure complies with the requirement to disclose how the chief operating decision maker uses your reported measure(s) of segment profit or loss in assessing segment performance and deciding how to allocate resources pursuant to ASC 280-10-50-29(f). Refer to ASC 280-10-55-47(bb) for guidance. Response The Company acknowledges the Staff’s comment and advises that its chief operating decision maker (“CODM”) regularly reviews segment-level operating income, along with revenue and gross margin information, to assess segment performance and allocate resources. The Company enhanced its segment disclosures beginning in its Form 10-Q for the quarter ended September 30, 2025 to more explicitly describe how the CODM uses segment-level financial information. The Company believes this disclosure complies with the requirements of ASC 280-10-50-29(f) and the illustrative guidance in ASC 280-10-55-47(bb). The Company will continue to include this enhanced disclosure in its future filings. The disclosure describes the specific measures reviewed by the CODM and how those measures are used in assessing performance and allocating resources. April 23, 2026 Page 3 Illustratively, the disclosure states that: “The CODM reviews key financial measures for each reportable segment based on various financial results including net sales, gross profit and operating income. These measures are assessed in the annual budget process as well as on an actual-to-budget comparison and an actual-to-forecast comparison when making decisions about the allocation of resources to each segment. In addition to financial results such as net sales, gross profit, and operating income, the CODM also considers a range of operational and financial metrics, including EBITDA, return on invested capital, customer metrics and other strategic indicators. These tools support a comprehensive view of performance and inform strategic decisions across our reportable segments.” Closing The Company acknowledges that it is responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, or actions by the Staff. If you have any questions regarding the foregoing responses, please feel free to contact me at (864) 286-4302. Sincerely, /s/ Steve Jones Steve Jones Senior Executive Vice President and Chief Financial Officer ScanSource, Inc.
2026-04-13 - CORRESP - SCANSOURCE, INC.
Read Filing Source Filing Referenced dates: March 13, 2026
CORRESP
 1
 filename1.htm

 Document April 13, 2026 VIA EDGAR SUBMISSION Office of Trade & Services Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: ScanSource, Inc. Form 10-K for the Fiscal Year Ended June 30, 2025 Filed August 21, 2025 File No. 000-26926 Ladies and Gentlemen: We are in receipt of your comment letter dated March 13, 2026 regarding the Securities and Exchange Commission’s review of the ScanSource, Inc. (the “Company”) Form 10-K for the fiscal year ended June 30, 2025. The need for the extension is due to the timing of the Company’s current Form 10-Q filing for the quarter ended March 31, 2026, which is due on May 11, 2026. The Company respectfully requests an extension until April 30, 2026. Sincerely, /s/ Steve Jones Steve Jones Executive Vice President and Chief Financial Officer ScanSource, Inc.
2026-03-13 - UPLOAD - SCANSOURCE, INC. File: 000-26926
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 13, 2026

Steve Jones
Senior Executive Vice President and Chief Financial Officer
ScanSource Inc.
6 Logue Court
Greenville , South Carolina 29615

 Re: ScanSource Inc.
 Form 10-K for the Fiscal Year Ended June 30, 2025
 Filed August 21, 2025
 File No. 000-26926
Dear Steve Jones:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended June 30, 2025
(1) Business and Summary of Significant Accounting Policies
Supplier Programs, page 53

1. Here you state "Incentives received from suppliers for specifically
identified incremental
 market development funds are recorded as adjustments to net sales."
However on page
 35, you state "Incentives received from suppliers for specifically
identified incremental
 market development funds are recorded as adjustments to selling, general
and
 administrative expenses." Please advise.
(16) Segment Information, page 79

2. Please tell us how your disclosure complies with the requirement to
disclose how the
 chief operating decision maker uses your reported measure(s) of segment
profit or loss in
 assessing segment performance and deciding how to allocate resources
pursuant to ASC
 280-10-50-29.f. Refer to ASC 280-10-55-47.bb for guidance.
 March 13, 2026
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.

 Please contact Aamira Chaudhry at 202-551-3389 or Abe Friedman at
202-551-8298
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>

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