-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, Al78H+4K8RJIpoaFuY6OuGIcc8JRjErkfDtLKtTXEl89OJ2OT2GsAEicdQLVw+d2 IfJ9m+WTGmgb53Zwe7HEWw== 0000000000-05-045350.txt : 20060821 0000000000-05-045350.hdr.sgml : 20060821 20050831163533 ACCESSION NUMBER: 0000000000-05-045350 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20050831 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: TUPPERWARE BRANDS CORP CENTRAL INDEX KEY: 0001008654 STANDARD INDUSTRIAL CLASSIFICATION: PLASTICS PRODUCTS, NEC [3089] IRS NUMBER: 364062333 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 14901 S ORANGE BLOSSOM TRAIL CITY: ORLANDO STATE: FL ZIP: 32837-6600 BUSINESS PHONE: (407) 826-5050 MAIL ADDRESS: STREET 1: P O BOX 2353 CITY: ORLANDO STATE: FL ZIP: 32802-2353 FORMER COMPANY: FORMER CONFORMED NAME: TUPPERWARE CORP DATE OF NAME CHANGE: 19960221 LETTER 1 filename1.txt Mail Stop 7010 August 31, 2005 Mr. Michael S. Poteshman Executive Vice President and CFO Tupperware Corporation 14901 South Orange Blossom Trail Orlando, FL 32837 RE: Form 10-K for the fiscal year ended December 25, 2004 Form 10-Q for the quarter ended April 2, 2005 Form 10-Q for the quarter ended July 2, 2005 File No. 1-11657 Dear Mr. Poteshman: We have reviewed these filings and have the following comments. If you disagree with a comment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as necessary in your explanation. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. FORM 10-Q FOR THE PERIOD ENDED JULY 2, 2005 General 1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like. These revisions should be included in your future filings. Financial Statements Note 3 - Promotional Accruals, page 7 2. We have reviewed your response to comment 2. We continue to believe that you should disclose the amount of promotional expenses that are included in the delivery, sales and administrative expense line item for each period presented. This information is necessary to enable comparison of gross margin between companies that classify these amounts differently. By not requiring disclosure of the amounts netted against revenues, the full amount of these activities is not known to the reader, which helps protect the confidentiality of the full amount. * * * * Please respond to these comments within 10 business days, or tell us when you will provide us with a response. Please provide us with a response letter that keys your responses to our comments and provides any requested information. Detailed letters greatly facilitate our review. Please file your supplemental response on EDGAR as a correspondence file. Please understand that we may have additional comments after reviewing your responses to our comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed decision. Since the company and its management are in possession of all facts relating to a company`s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing. If you have any questions regarding these comments, please direct them to Jeffrey Gordon, Staff Accountant, at (202) 551-3866 or, in his absence, to the undersigned at (202) 551-3769. Sincerely, Rufus Decker Accounting Branch Chief ?? ?? ?? ?? Mr. Michael S. Poteshman Tupperware Corporation August 31, 2005 Page 1 of 3 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE -----END PRIVACY-ENHANCED MESSAGE-----