Letterhead of Barbara R. Smith
Senior Vice President and Chief Financial Officer
Commercial Metals Company
Post Office Box 1046
Dallas, Texas 75221-1046
6565 North MacArthur Blvd., Suite 800
Irving, Texas 75039
Phone: 972-308-5199
April 24, 2012
Via EDGAR and Federal Express
Mr. John Cash
Branch Chief
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
Re: | Commercial Metals Company |
Form 10-K for the fiscal year ended August 31, 2011
Filed October 31, 2011
Form 10-Q for the quarter ended February 29, 2012
Filed April 6, 2012
File No. 1-4304
Dear Mr. Cash:
Commercial Metals Company (the Company) received your letter dated April 17, 2012 by fax on April 17, 2012. The Company submits the following response to your letter which for ease of reference is replicated by point.
Form 10-Q for the Quarterly Period Ended February 29, 2012
Managements Discussion and Analysis . . . . page 18
Liquidity and Capital Resources, page 23
Cash Flows, page 24
We note you reference your days sales outstanding and days sales in inventory as compared to the same period in the prior year. However, you do not provide the comparison from the same period in the prior year. When making these types of disclosures in future filings, please also provide the applicable comparison. For example, disclosing the days sales outstanding and days sales in inventory from the same period in the prior year would provide more context for the comparison you seek to make.
Response:
The Company acknowledges the Staffs comment and will provide comparative disclosures for financial measures, including days sales outstanding and days sales in inventory, when presented in future filings.
Mr. John Cash
April 24, 2012
Page 2
The Company acknowledges the following:
| the Company is responsible for the adequacy and accuracy of the disclosure in its filing; and |
| 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. |
Please contact the undersigned at (972) 308-5199 or Leon K. Rusch at (214) 689-5419 if you have any questions or would like additional information in respect to these responses.
Very truly yours,
/s/ Barbara R. Smith
cc: | Joseph Alvarado, Chairman, President and Chief Executive Officer |
Ann J. Bruder, Senior Vice President, General Counsel and Corporate Secretary
Leon K. Rusch, Vice President and Controller
Audit Committee of Board of Directors
Paul L. Choi, Sidley Austin, LLP
Jeffry S. Plowman, Deloitte & Touche, LLP