CORRESP 1 filename1.htm corresp
June 8, 2009
Mr. Praveen Kartholy
Reviewing Accountant
U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington, D.C. 20549
Mr. Brian Cascio
Accounting Branch Chief
U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington, D.C. 20549
RE:    Anixter International Inc.
Form 10-K for the fiscal year ended January 2, 2009
Filed February 27, 2009
File No. 001-10212
We are in receipt of your follow-up letter to Dennis J. Letham dated June 5, 2009, containing the following comment. In the attached document, the SEC comment is in bold type and our management response is directly below the comment.
If you have any questions please call me at 224-521-8601. You can also contact the individuals below.
         
Todd Heeter
  Director of Financial Reporting   224-521-8568 
Terry Faber
  Vice President — Controller   224-521-8715 
         
Sincerely,
 
   
/s/ Dennis J. Letham      
Dennis J. Letham     
Executive Vice President — Finance
Chief Financial Officer 
   

 


 

         
Form 10-K for the fiscal year ended January 2, 2009
Legal Proceedings, page 6
1.   In future filings, please disclose that the countries your foreign subsidiaries may have re-exported goods to in violation of export control laws include Cuba and Syria, countries identified by the State Department as state sponsors of terrorism.
Management’s Response
    Until the matter is resolved with the U.S. Department of Treasury and Commerce, we propose to include, at the end of the first paragraph under the “Legal Proceedings” section of each future form 10-Q and 10-K, the following language: “including Cuba and Syria, countries identified by the State Department as state sponsors of terrorism.”