Re: | Ennis, Inc. Form 10-K for the year ended February 29, 2009 Filed May 11, 2009 |
1. | In future filings, please provide the correct address of the SEC public reference room, which is now 100 F Street NE, Washington, D.C. 20549. | ||
Response: The Company will incorporate the above mentioned address change in all future filings. |
2. | Refer to the first paragraph under your discussion of Net Earnings. In future filings, please delete the last sentence that begins with Without the impairment charge and certain other unusual items...our diluted earnings per share for the current year would have been $1.46 per share. Such disclosure represents a non-GAAP measure of net earnings per share. Alternatively, you may revise this sentence to disclose the dollar impact that each of these items |
had on your diluted earnings per share, without providing a total that represents diluted earnings per share that has been adjusted for these various items. Refer to Item 10(e)(1)(ii) of Regulation S-K. |
3. | Refer to the paragraph discussion of Profit by Segment for the Apparel Segment on page 22. Similar to the above comment, your discussion of Apparel segment profits that excludes the non-cash impairment charges and certain other unusual charges represents a non-GAAP profitability measure that should be deleted from the filing, or alternatively, revised to discuss the individual dollar (or percentage) impact that each of these items had on segment profitability. Please revise future filings. Refer to Item 10(e)(1)(ii) of Regulation S-K. |
4. | In future filings please separately disclose the amount of goodwill impairment from that of other intangibles (i.e., trademarks). We refer you to FASB ASC 350-20-45-2 (previously FASB No. 142, paragraph 43). |
5. | Refer to the sentence that begins with In the opinion of management, all adjustments considered necessary...have been included. Please expand to also disclose whether all adjustment were of a normal recurring nature. See Rule 10-01(b)(8) of Regulation S-X. |
| 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 period under the federal securities laws of the United States. |
If you have any questions concerning these responses, please call me at 972-775-9805. |
C.c.
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Wally Gruenes, Grant Thornton LLP | |
Norman Miller, Winstead PC |