-----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, QIqjnUbaWTH+iDJ46seTo/FvWcoNcAsEXmK0q7SzetKfRDgqQxfYeMVYZtSHwqHP wmahQfZbxkqlFDOSFx9a6Q== 0001171520-07-000877.txt : 20080219 0001171520-07-000877.hdr.sgml : 20080218 20071221141846 ACCESSION NUMBER: 0001171520-07-000877 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20071221 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WATTS WATER TECHNOLOGIES INC CENTRAL INDEX KEY: 0000795403 STANDARD INDUSTRIAL CLASSIFICATION: MISCELLANEOUS FABRICATED METAL PRODUCTS [3490] IRS NUMBER: 042916536 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 815 CHESTNUT ST CITY: NORTH ANDOVER STATE: MA ZIP: 01845 BUSINESS PHONE: 9786881811 MAIL ADDRESS: STREET 1: 815 CHESTNUT STREET CITY: NORTH ANDOVER STATE: MA ZIP: 01845 FORMER COMPANY: FORMER CONFORMED NAME: WATTS INDUSTRIES INC DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.txt December 21, 2007 Via EDGAR Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-7010 Attention: John Cash, Accounting Branch Chief Re: Watts Water Technologies, Inc. Form 10-K for the Fiscal Year Ended December 31, 2006 Form 10-Q for the Fiscal Quarter Ended April 1, 2007 Form 10-Q for the Fiscal Quarter Ended July 1, 2007 Form 10-Q for the Fiscal Quarter Ended September 30, 2007 File No. 001-11499 Dear Mr. Cash: On behalf of Watts Water Technologies, Inc. (the "Company"), I have set forth below responses to the comments to the Company's Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2006 and Quarterly Reports on Form 10-Q for the Fiscal Quarters Ended April 1, 2007, July 1, 2007, and September 30, 2007, provided to me in your letter dated December 19, 2007 (the "Letter"). The responses are keyed to the numbering of the comments in the Letter and to the headings used in the Letter. Form 10-K for the Fiscal Year Ended December 31, 2006 Consolidated Statements of Cash Flows, page 61 1. We note that in your presentation of operating activities under the indirect method, you begin with a reconciliation of "income from continuing operations." In future filings, please revise your statements of cash flows to begin your reconciliation with "net income" as required by paragraph 28 of SFAS 95. Response The Company respectfully acknowledges the Staff's comment and will revise its disclosure in future filings. Securities and Exchange Commission Attn: John Cash, Accounting Branch Chief December 21, 2007 Page 2 Note 17 - Segment Information, page 94 2. In future filings, please revise your disclosure to include a reconciliation of your total of your segments' measure of profit or loss, which appears to be operating income (loss), to your consolidated income from continuing operations before income taxes as required by paragraph 32(b) of SFAS 131. Response The Company respectfully acknowledges the Staff's comment and will revise its disclosure in future filings. Form 10-Q for the Fiscal Quarter Ended September 30, 2007 Note 5 - Restructuring and Other Charges, page 12 3. We note your initiation of a global restructuring program and the continued discontinuance of certain product lines during the third quarter of 2007. In this regard, we remind you follow the disclosure requirements as provided by paragraph 20 of SFAS 146 and provide the reconciliation of the liability balance as provided in paragraph 20b(2) of SFAS 146. Response The Company respectfully acknowledges the Staff's comment and will include such disclosure in future filings. The Company hereby acknowledges that: (i) it is responsible for the adequacy and accuracy of the disclosure in its filings; (ii) 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 (iii) the Company may not assert the Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Securities and Exchange Commission Attn: John Cash, Accounting Branch Chief December 21, 2007 Page 3 Please telephone the undersigned at (978) 689-6207 with any questions or comments concerning this filing. Very truly yours, /s/ William C. McCartney - ------------------------ William C. McCartney Chief Financial Officer Cc: Dale Welcome -----END PRIVACY-ENHANCED MESSAGE-----