SNASnap-on

We note in your Management Overview and your Results of Operations that you often attribute changes in your results to a combination of several different factors. We further note that certain factors attributed to your results are vague.

Rest of the question

For example, on page 26 you attribute the organic sales increase in your Commercial and Industrial Group to higher sales to customers in “critical industries” and in the segment’s European-based hand tools business. We further note that you refer to “rapid continuous improvement” or “RCI” in your discussion and analysis of your results. However, you do not provide an explanation as to what you mean by “critical industries” or what your rapid continuous improvement initiative entails. When you list multiple factors that contributed to changes in your results, in future filings please quantify, if possible, the impact of each material factor that you discuss and explain each factor, where necessary, to provide your readers with better insight into the underlying reasons behind the changes in your results.

The company acknowledges the Staff’s comment and confirms that its future filings, including the company’s third quarter 2015 Form 10-Q, will more fully define and quantify, where practicable, the impact of each material factor discussed and will further expand disclosures and descriptions, where necessary, to provide readers with better insight into the underlying reasons behind the changes in our results. Read in the reply ↗