CORRESP: Correspondence
Published on
DORMAN
New Since 1918
May 13, 2008
Ms. Linda Cvrkel
Branch Chief
Securities and Exchange Commission
100 F Street, N.E., Mail Stop 3561
Washington, D.C. 20549
RE: Dorman Products, Inc. Form 10-K for the fiscal year ended
December 27, 2007 - File No. 0-18914
Dear Ms. Cvrkel:
Enclosed are our responses to your follow up letter dated May 6, 2008
(the "Comment Letter"). In order to facilitate your review, we have included
the Staff's comment followed by our response below.
Item 7. Management's Discussion and Analysis of Financial Condition
and Results of Operations Change in Vacation Policy
1. We note your response to previous comment #1. Please add disclosure
in future filings to clarify in detail the changes in your vacation policy that
resulted in the reduction of your vacation accrual.
Response:
In filings through fiscal 2009, we will revise the "Vacation Policy"
disclosure in the footnotes to the financial statements and
Management's Discussion and Analysis of Financial Condition and Results
of Operations to read as follows:
Effective December 31, 2006, we changed our vacation policy so that
the current year's vacation time is earned ratably throughout the
current year. Prior to December 31, 2006, all rights to the
subsequent year's vacation vested to our employees on the last day of
the previous fiscal year and the corresponding liability was recorded
in that previous year. Since employees had vested all 2007 vacation
time prior to the beginning of 2007 under the old policy, no
additional vacation time was earned in 2007 and no expense was
recorded. This change resulted in a reduction in our vacation accrual
of approximately $1.8 million in 2007. As a result, vacation expense
in cost of goods sold and selling, general and administrative expenses
was reduced during each of the fiscal quarters in 2007. Results for
the three months ended March 31, 2007 include vacation expense
reductions of $0.1 million in cost of goods sold and $0.3 million
in selling, general and administrative expenses.
Other
2. Your response letter datedApril 16, 2008 should be submitted in
electronic form, under the label corresp.
Response:
We have submitted our April 16, 2008 response letter in
electronic form.
If you or any other member of the Staff have any questions or would
like to discuss these matters at greater length, please do not hesitate to
contact me at(215) 712-5132 or, in my absence, Thomas Knoblauch, at (215)
712-5222.
Sincerely,
Mathias J. Barton
Chief Financial Officer
cc: Ms. Effie Simpson, Division of Corporation Finance
Richard N. Berman, Chairman and Chief Executive Officer
Thomas Knoblauch, Esq., Vice President - General Counsel
Jane K. Storero, Esq., Blank Rome LLP