-----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, Ny6P9NV4jf6XOTy+LLunaeXI+vl7GRAIf0VeWcAh8CFSAWvC0DW8757xVaqc9T+h 5wLWH80chu6KiPtIHntQOg== 0000000000-05-059049.txt : 20060926 0000000000-05-059049.hdr.sgml : 20060926 20051122140552 ACCESSION NUMBER: 0000000000-05-059049 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20051122 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: HANSEN NATURAL CORP CENTRAL INDEX KEY: 0000865752 STANDARD INDUSTRIAL CLASSIFICATION: BOTTLED & CANNED SOFT DRINKS CARBONATED WATERS [2086] IRS NUMBER: 391679918 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 1010 RAILROAD STREET CITY: CORONA STATE: CA ZIP: 92882 BUSINESS PHONE: 909-739-6200 MAIL ADDRESS: STREET 1: 1010 RAILROAD STREET CITY: CORONA STATE: CA ZIP: 92882 FORMER COMPANY: FORMER CONFORMED NAME: UNIPAC CORP DATE OF NAME CHANGE: 19600201 PUBLIC REFERENCE ACCESSION NUMBER: 0000865752-05-000008 LETTER 1 filename1.txt Mail Stop 3561 November 22, 2005 Mr. Rodney C. Sacks Chairman of the Board and Chief Executive Officer Hansen Natural Corporation 1010 Railroad Street Corona, California 92882 RE: Hansen Natural Corporation Form 10-K for Fiscal Year Ended December 31, 2004 Form 10-Q for Fiscal Quarter Ended September 30, 2005 Filed March 16, 2005 and November 9, 2005 File No. 0-18761 Dear Mr. Sacks: We have reviewed your responses in your letter dated November 11, 2005 and have the following additional comments. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Form 10-K for Fiscal Year Ended December 31, 2004 Notes to Consolidated Financial Statements General 1. We read your response to comment 2 in our letter dated October 13, 2005. We object to your proposal to change your segment reporting beginning with your Form 10-K for the year-ended December 31, 2005. Based on the supplemental financial reporting package you submitted in response to our August 1, 2005 comment letter you reported results to the CODM at a more detailed level than one reportable segment for the year ended December 31, 2004. There appears to be no substantive difference, from a SFAS 131 perspective, between your segment reporting in 2004 and currently, other than that your current internal reporting aggregates into one operating and reportable segment the operations of four operating segments for which discrete financial information was previously prepared. In light of the significant difference between the economic characteristics of the DSD operating segment and the other operating segments, which are now aggregated and reported as the Warehouse segment, please amend your Form 10-K to provide all required segment information for your two reportable segments, including product line disclosures, in an audited note for all periods presented. Ensure that your amended disclosure provides all information required by paragraphs 26-28 of SFAS 131. Please also ensure that your amended disclosure reconciles each segment measure to reported consolidated amounts as required by paragraph 32 of SFAS 131. Form 10-Q for the Quarter Ended September 30, 2005 Condensed Consolidated Statements of Cash Flows, page 5 2. Please tell us how you classify short-term investments for purposes of SFAS 115. Based on the nature of the investments you hold as disclosed in Note 2 and the short time frame over which investments are held we assume that you designate your short-term investments as trading securities in accordance with paragraph 12(a) of SFAS 115. If so, please tell us why you classify purchases and sales of short-term investments as investing activities on the statements of cash flows. Refer to paragraph 18 of SFAS 115 for guidance. As appropriate, please respond to these comments within 10 business days or tell us when you will provide us with a response. Please ensure the response letter provides any requested supplemental information. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your response to our comments. If you have any questions regarding these comments, please direct them to Anthony Watson, Staff Accountant, at (202) 551-3318 or, in his absence, to me at (202) 551-3843. Sincerely, George F. Ohsiek, Jr. Branch Chief ?? ?? ?? ?? Mr. Rodney C. Sacks Hansen Natural Corporation November 22, 2005 Page 3 -----END PRIVACY-ENHANCED MESSAGE-----