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Baker & McKenzie LLP |
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2300 Trammell Crow Center |
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2001 Ross Avenue |
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Dallas, TX 75201 |
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United States |
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Tel: +1 214 978 3000 |
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Fax: +1 214 978 3099 |
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www.bakermckenzie.com |
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Asia Pacific Bangkok Beijing Brisbane Hanoi Ho Chi Minh City Hong Kong Jakarta* Kuala Lumpur* Manila* Melbourne Seoul Shanghai Singapore Sydney Taipei Tokyo Yangon
Europe, Middle East & Africa Abu Dhabi Almaty Amsterdam Antwerp Bahrain Baku Barcelona Berlin Brussels Budapest Cairo Casablanca Doha Dubai Dusseldorf Frankfurt/Main Geneva Istanbul Jeddah* Johannesburg Kyiv London Luxembourg Madrid Munich |
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October 30, 2015
Via Edgar- Correspondence Only United States Securities and Exchange Commission Division of Corporation Finance
Attention: Mr. Larry Spirgel
Re: Helen of Troy Limited
Dear Mr. Spirgel,
On behalf of our client, Helen of Troy Limited (the “Company”), we submit this letter in response to the verbal comment by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received during a telephone conversation on October 22, 2015.
In response to the Staff’s comment, the Company will provide additional disclosure in the Company’s future annual reports as to its ability to satisfy the thresholds applicable to maintaining its eligibility to receive the Macau tax holiday that has been granted to the Company’s Macau subsidiary.
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In response to the Staff’s request, the Company has acknowledged certain matters on Exhibit A attached hereto. Should you have any additional questions or comments, please do not hesitate to contact me at (214) 978-3042 or Vince Carson of the Company at (915) 225-8033. | |
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Paris Prague Riyadh* Rome St. Petersburg Stockholm Vienna Warsaw Zurich
Latin America Bogota Brasilia** Buenos Aires Caracas Guadalajara Juarez Lima Mexico City Monterrey Porto Alegre** Rio de Janeiro** Santiago Sao Paulo** Tijuana Valencia
North America Chicago Dallas Houston Miami New York Palo Alto San Francisco Toronto Washington, DC
* Associated Firm ** In cooperation with Trench, Rossi e Watanabe Advogados |
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Regards, | |
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/s/ W. Crews Lott |
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W. Crews Lott Partner 214-978-3042 Crews.Lott@bakermckenzie.com | ||
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Encl.
Cc: Terry French
Helen of Troy Limited Brian L. Grass Vincent D. Carson | ||
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Baker & McKenzie LLP is a member of Baker & McKenzie International, a Swiss Verein. | ||
Exhibit A
October 30, 2015
Via Edgar- Correspondence Only
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 3720
Washington, DC 20549-7010
In response to the request of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), Helen of Troy Limited (the “Company”) acknowledges to the Staff 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.
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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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