HELEN OF TROY LIMITED
Clarendon House
2 Church Street
Hamilton, Bermuda
October 13, 2015
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United States Securities and Exchange Commission |
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By EDGAR |
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 3720
Washington, DC 20549-7010
Attention: Mr. Larry Spirgel
Re: Helen of Troy Limited
Form 10-K for Fiscal Year Ended February 28, 2015
Filed April 29, 2015
File No. 1-14669
Dear Mr. Spirgel:
Helen of Troy Limited (the “Company”) submits this letter to supplement the letter sent on its behalf by Baker & McKenzie LLP dated October 8, 2015 in response to the written comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated September 10, 2015 (the “Comment Letter”) relating to the above-referenced Form 10-K.
In response to your request in the Comment Letter, the Company acknowledges that:
· 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 person under the federal securities laws of the United States.
Should you have any additional questions or comments, please do not hesitate to contact Crews Lott at (214) 978-3042 or me at (915) 225-8033.
Regards,
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/s/ Vincent D. Carson |
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Vincent D. Carson |
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Chief Legal Officer and Secretary |
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