-----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, HbdCsDR1vXRvBlSv3UFaxWSZG7aN6vipLeu3/QGB0rdy4iTmNi+U2/2THBjkRXx6 1zvmIOtb8dcUFMdsP7Vfkg== 0000000000-06-011253.txt : 20061113 0000000000-06-011253.hdr.sgml : 20061110 20060307143639 ACCESSION NUMBER: 0000000000-06-011253 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060307 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: BOSTON BEER CO INC CENTRAL INDEX KEY: 0000949870 STANDARD INDUSTRIAL CLASSIFICATION: MALT BEVERAGES [2082] IRS NUMBER: 043284048 STATE OF INCORPORATION: MA FISCAL YEAR END: 1226 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: 75 ARLINGTON ST CITY: BOSTON STATE: MA ZIP: 02116 BUSINESS PHONE: 6174821332 MAIL ADDRESS: STREET 1: 75 ARLINGTON ST STREET 2: 5TH FL CITY: BOSTON STATE: MA ZIP: 02110 PUBLIC REFERENCE ACCESSION NUMBER: 0000950135-05-001351 LETTER 1 filename1.txt Mail Stop 3561 March 7, 2006 Mr. Martin F. Roper President and Chief Executive Officer The Boston Beer Company, Inc. 75 Arlington Street Boston, Massachusetts 02116 RE: The Boston Beer Company, Inc. Form 10-K for Fiscal Year Ended December 25, 2004 Form 10-Q for Fiscal Quarter Ended September 24, 2005 Filed March 11, 2005 and November 3, 2005 File No. 1-14092 Dear Mr. Roper: We have reviewed your responses in your letter dated February 24, 2006 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 25, 2004 Notes to Consolidated Financial Statements, page 32 B. Summary of Significant Accounting Policies, page 30 Segment Reporting, page 34 1. We read your response to comment 1 in our letter dated February 7, 2006. In order to better understand how you concluded that you have only one operating segment, please provide us the following: * The name and position of your chief operating decision maker; * A complete copy of the year end December 25, 2004, as well as most recent, internal management report provided to your chief operating decision maker that includes your operating results; * A copy of the package given to the Board of Directors for the same time periods; and * An organizational chart detailing your management structure under the chief operating decision maker as it relates to managing the operational aspects of your business. Additionally, please tell us the measure(s) that your CODM uses to evaluate and allocate resources to your business. For each measure that you list, please provide us your computation of these measures for the last five years. If after reassessing the criteria in SFAS 131, you now believe that you have separate operating and reportable segments, please revise your future financial statements accordingly. 2. We read your response to comment 2 in our letter dated February 7, 2006. Please provide us with a copy of the most recent monthly report(s) provided to senior management for purposes of managing the business. Please note that if providing disclosure of product line revenue information is impracticable you should so state in accordance with paragraph 37 of SFAS 131. Also, refer to Section II.J.3. of the Current Accounting and Disclosure Issues in the Division of Corporation Finance updated March 4, 2005 and available on our website at www.sec.gov. 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 this comment, 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. Martin F. Roper The Boston Beer Company, Inc. March 07, 2006 Page 3 -----END PRIVACY-ENHANCED MESSAGE-----