-----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, VKXEUpm7soaglGjK5EsTkKkaMx979hu/rM2mJ2y3rIs1n+fV4dSNKnbLWtBBwZfi BZl/m++nM1oNI2cQTEdOOg== 0000000000-06-015328.txt : 20061207 0000000000-06-015328.hdr.sgml : 20061207 20060331091436 ACCESSION NUMBER: 0000000000-06-015328 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060331 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: PHILLIPS VAN HEUSEN CORP /DE/ CENTRAL INDEX KEY: 0000078239 STANDARD INDUSTRIAL CLASSIFICATION: MEN'S & BOYS' FURNISHINGS, WORK CLOTHING, AND ALLIED GARMENTS [2320] IRS NUMBER: 131166910 STATE OF INCORPORATION: DE FISCAL YEAR END: 0131 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 200 MADISON AVENUE CITY: NEW YORK STATE: NY ZIP: 10016 BUSINESS PHONE: 2123813500 MAIL ADDRESS: STREET 1: 200 MADISON AVENUE CITY: NEW YORK STATE: NY ZIP: 10016 PUBLIC REFERENCE ACCESSION NUMBER: 0000078239-05-000009 LETTER 1 filename1.txt Mail Stop 3561 March 30, 2006 By Facsimile and U.S. Mail Mr. Vincent Russo Chief Accounting Officer Phillips-Van Heusen Corporation 200 Madison Avenue New York, New York 10016 Re: Phillips-Van Heusen Corporation Form 10-K for the year ended January 30, 2005 Filed April 14, 2005 File No. 1-07572 Dear Mr. Russo: We reviewed your responses to our prior comments on the above referenced filings as set forth in your letter dated March 22, 2006. Our review resulted in the following accounting comment. Form 10-K for the Year Ended January 30, 2005 1. We note your response to comment four of our letter dated February 9, 2006. Paragraph 17 of SFAS 131 and EITF Issue no. 04-10 indicate that operating segments must have similar economic characteristics in order to justify aggregation into one reportable segment. Further, aggregation of operating segments requires that all aggregation criteria are met in the case of operating segments that exceed certain quantitative thresholds. It appears that the gross margins for the three years ended 2004 are materially different among your operating segments. Furthermore, it does not appear that your wholesale and retail businesses represent similar distribution channels. It appears that footwear and clothing such as shirts are not similar products given the different materials used to produce these products and the general nature of the product itself. Please revise your segment disclosures included in the notes to the financial statements included in your Form 10-K for the year ended January 29, 2006. Provide to us a draft of your proposed disclosure and the justification for aggregation of operating segments into reportable segments. ```````````````````````````````````````````````As appropriate, please respond to this comment 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 response to our comment and provides any requested supplemental information. Please file your response letter on EDGAR as a correspondence file. ` If you have any questions regarding this comment, please direct them to Robert Babula, Staff Accountant, at (202) 551-3339 or, in his absence, to the undersigned at (202) 551-3841. Any other questions regarding disclosures issues may be directed to H. Christopher Owings, Assistant Director at (202) 551-3725. Sincerely, Michael Moran, Esq. Branch Chief ?? ?? ?? ?? Mr. Vincent Russo Phillips-Van Heusen Corporation March 30, 2006 Page 2 -----END PRIVACY-ENHANCED MESSAGE-----