-----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, C1/IdlJBHuJ8NvjVDLvCv4Hl31wAf7RbijKBYTSViIoCFM4476QWtnHwxazu9m9T g/NgeQ2NH7xUpb64n4o0yg== 0000950137-08-010828.txt : 20081006 0000950137-08-010828.hdr.sgml : 20081006 20080815120951 ACCESSION NUMBER: 0000950137-08-010828 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20080815 FILER: COMPANY DATA: COMPANY CONFORMED NAME: COLLECTIVE BRANDS, INC. CENTRAL INDEX KEY: 0001060232 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-SHOE STORES [5661] IRS NUMBER: 431813160 STATE OF INCORPORATION: DE FISCAL YEAR END: 0130 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 3231 SOUTH EAST SIXTH STREET CITY: TOPEKA STATE: KS ZIP: 66607-2207 BUSINESS PHONE: 7852335171 MAIL ADDRESS: STREET 1: 3231 S E 6TH ST CITY: TOPEKA STATE: KS ZIP: 66607-2207 FORMER COMPANY: FORMER CONFORMED NAME: PAYLESS SHOESOURCE INC /DE/ DATE OF NAME CHANGE: 19980903 FORMER COMPANY: FORMER CONFORMED NAME: PAYLESS SHOESOURCE HOLDINGS INC DATE OF NAME CHANGE: 19980421 CORRESP 1 filename1.htm corresp
Collective Brands, Inc.
3231 SE 6th Avenue
Topeka, Kansas 66607
August 15, 2008
VIA EDGAR TRANSMISSION
Mr. John Reynolds
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 3561
100 F Street, N.E.
Washington, D.C. 20549
Re:   Collective Brands, Inc.
Form 10-K for Fiscal Year Ended February 2, 2008
Filed April 1, 2008
Definitive Proxy Statement
Filed April 16, 2008
Dear Mr. Reynolds:
Collective Brands, Inc. has received your letter dated July 31, 2008 containing comments on the filings referenced above. This letter on behalf of the company responds to those comments.
For convenience of reference, we have included your comments in this letter, and our response to each comment follows it.
Proxy Statement
SEC Comment: We note that you benchmark to the HayGroup Retail Compensation Survey as well as the Compensation Comparison Group. In future filings, please identify the companies that make up this survey, or, to the extent the names of the companies are not known by the compensation committee, provide clear disclosure.
Response: If the Company utilizes the HayGroup Retail Compensation Survey (the “Survey”) or similar surveys in the future, in future filings, the Company will identify the companies comprising the survey to the extent disclosed to the Compensation Committee or if not known by the Committee will provide clear disclosure of that fact.

 

 

In connection with responding to your comments on our filings, as set forth above, we acknowledge that:
  •   we are responsible for the adequacy and accuracy of the disclosure in the filings;
 
  •   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
 
  •   we 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.
Sincerely,
/s/ Harold J. Herman II
Harold J. Herman II
Vice President, Group Counsel and Assistant Secretary
cc:   Mattew E. Rubel, Chairman, Chief Executive Officer and President
Ullrich E. Porzig, Senior Vice President, Chief Financial Officer and Treasurer
Michael J. Massey, Senior Vice President, General Counsel and Secretary

 

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