April 28, 2014
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
Attention: William H. Thompson, Accounting Branch Chief
Re: | MarineMax, Inc. |
Form 10-K for the Fiscal Year Ended September 30, 2013 |
Filed December 6, 2013 |
File No. 001-14173 |
Dear Mr. Thompson:
On behalf of MarineMax, Inc. (“MarineMax”), I am writing in response to certain telephone conversations over the past few days between Scott Stringer, Staff Accountant, and our counsel at Holland & Knight LLP.
My understanding is that, to assist the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC”) in its evaluation of the response of MarineMax dated April 4, 2014, the Staff asked that MarineMax provide certain additional information. Specifically, the Staff asked that MarineMax provide cost of sales and gross profit calculations for its products and services under two alternatives: (1) with brokerage reflected in the “Products and Rentals” line item and (2) with brokerage reflected in the “Service” line item. These calculations are presented below.
The below table reflects brokerage in the “Products and Rentals” line items.
2011 | 2012 | 2013 | ||||||||||
Revenue: | ||||||||||||
Products and Rentals | 438,508 | 479,791 | 537,045 | |||||||||
Service | 42,386 | 44,665 | 47,452 | |||||||||
|
|
|
|
|
| |||||||
Total Revenue | 480,894 | 524,456 | 584,497 | |||||||||
|
|
|
|
|
| |||||||
Cost of Sales: | ||||||||||||
Products and Rentals | 344,423 | 374,213 | 416,488 | |||||||||
Service | 16,977 | 16,960 | 17,156 | |||||||||
|
|
|
|
|
| |||||||
Total Cost of Sales | 361,400 | 391,173 | 433,644 | |||||||||
|
|
|
|
|
| |||||||
Gross Profit: | ||||||||||||
Products and Rentals | 94,085 | 105,578 | 120,557 | |||||||||
Service | 25,409 | 27,705 | 30,296 | |||||||||
|
|
|
|
|
| |||||||
Total Gross Profit | 119,494 | 133,283 | 150,853 | |||||||||
|
|
|
|
|
|
Securities and Exchange Commission
April 28, 2014
Page 2 of 3
The below table reflects brokerage in the “Service” line items.
2011 | 2012 | 2013 | ||||||||||
Revenue: | ||||||||||||
Products and Rentals | 425,951 | 467,488 | 523,230 | |||||||||
Service | 54,943 | 56,968 | 61,267 | |||||||||
|
|
|
|
|
| |||||||
Total Revenue | 480,894 | 524,456 | 584,497 | |||||||||
|
|
|
|
|
| |||||||
Cost of Sales: | ||||||||||||
Products and Rentals | 344,423 | 374,213 | 416,488 | |||||||||
Service | 16,977 | 16,960 | 17,156 | |||||||||
|
|
|
|
|
| |||||||
Total Cost of Sales | 361,400 | 391,173 | 433,644 | |||||||||
|
|
|
|
|
| |||||||
Gross Profit: | ||||||||||||
Products and Rentals | 81,528 | 93,275 | 106,742 | |||||||||
Service | 37,966 | 40,008 | 44,111 | |||||||||
|
|
|
|
|
| |||||||
Total Gross Profit | 119,494 | 133,283 | 150,853 | |||||||||
|
|
|
|
|
|
Finally, as the Staff considers this information, MarineMax believes it is worth noting that as its industry recovers and boat sales rise (trends MarineMax believes are consistent with recent facts), MarineMax believes the services revenue of MarineMax over the next few years will very likely be less than 10% of its total revenue regardless of how brokerage is classified.
* * *
MarineMax acknowledges the following:
• | MarineMax is responsible for the adequacy and accuracy of the disclosure in its Commission filings; |
• | 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 |
• | MarineMax may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
MarineMax believes that the foregoing responds fully to Mr. Stringer’s verbal requests. Please let us know if you have any questions about our responses.
Securities and Exchange Commission
April 28, 2014
Page 3 of 3
Respectfully submitted, | ||
MarineMax, Inc. | ||
By: | /s/ Michael H. McLamb | |
Michael H. McLamb | ||
Chief Financial Officer |
cc: | William H. McGill, Jr., Chief Executive Officer, MarineMax, Inc. |
Paulee Day, General Counsel, MarineMax, Inc. |
Robert J. Grammig, Esq., Holland & Knight LLP |
Steven W. McMullen, Partner, KPMG LLP |