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United States securities and exchange commission logo
January 26, 2022
Neal S. Nackman
Chief Financial Officer
G-III Apparel Group, Ltd.
512 Seventh Avenue
New York, New York 10018
Re: G-III Apparel
Group, Ltd.
Form 10-K for The
Fiscal Year Ended January 31, 2021
Filed March 26,
2021
File No. 000-18183
Dear Mr. Nackman:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended January 31, 2021
Item 7. Management's Discussion And Analysis Of Financial Condition And
Results Of
Operation.
Use of Estimates and Critical Accounting Policies
Goodwill and Intangible Assets, page 51
1. We note that goodwill
and indefinite-lived trademarks are material to total assets and
equity and we also note
the decline in your market capitalization. In order to provide
information for
investors to better assess the probability of future impairment charges,
please expand your
disclosures to indicate whether you believe the estimated fair values of
your wholesale
reporting unit and your indefinite-lived trademarks are substantially in
excess their carrying
values and also more fully explain the nature and composition of
your trademark balance.
If the estimated fair values of the wholesale reporting unit and/or
any indefinite-lived
trademark are not substantially in excess their carrying values, please
more fully address the
following:
Neal S. Nackman
G-III Apparel Group, Ltd.
January 26, 2022
Page 2
disclose the percentages by which the estimated fair values
exceed the carrying
values at the date of the most recent impairment test;
provide a more detailed description of the key assumptions used
to estimate fair
values, including how the key assumption was determined;
discuss the degree of uncertainty associated with the key
assumptions and provide a
sensitivity analysis of the potential impact of changes in the
key assumptions on your
impairment analyses; and
describe the potential events and/or changes in circumstances
that could reasonably
be expected to negatively affect the key assumptions.
Please refer to Item 303(b)(3) of Regulation S-K.
Item 8. Financial Statements And Supplementary Data
Consolidated Financial Statements
Note O - Segments, page F-36
2. Please disclose net sales by product line/product brand based on the
requirements of ASC
280-10-50-40. In this regard we note that you calculate historical
return rates and other
historical rates related to variable consideration on a product line
basis and you disclose
and discuss changes in net sales related to product brands in MD&A.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Andi Carpenter at 202-551-3645 or Anne McConnell at
202-551-3709
with any questions.
FirstName LastNameNeal S. Nackman Sincerely,
Comapany NameG-III Apparel Group, Ltd.
Division of
Corporation Finance
January 26, 2022 Page 2 Office of
Manufacturing
FirstName LastName