corresp
Since
1924
The
First Name in Avocados
May 6, 2008
Via Electronic Transmission and Federal Express
Mr. John Reynolds
Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 3561
Washington, D.C. 20549-3561
|
|
|
|
|
|
|
Re:
|
|
Calavo Growers, Inc. Annual Report on Form 10-K Filed January 14, 2008 File No. 000-33385 |
Dear Mr. Reynolds:
By letter dated April 30, 2008, you provided Calavo Growers, Inc., a California corporation
(the Company), with one comment regarding the disclosure on page 22 of the Proxy Statement filed
by the Company on February 28, 2008. Specifically, you requested that the Companys future filings
contain quantitative disclosure of all of the terms of the performance objectives for the bonus
awards for which the Companys executive officers are eligible.
In future filings of its Annual Report on Form 10-K and Annual Proxy Statement, the Company
will comply with the comment that is set forth in your letter by disclosing the formula and the
specific performance objectives used to determine its executive officers cash bonus awards.
The Company hereby acknowledges that:
1. The Company is responsible for the adequacy and accuracy of the disclosures in its filings
with the Securities and Exchange Commission (the Commission);
2. Comments from the staff of the Commission or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action with respect to the Companys
filings; and
3. The Company may not assert comments from the staff of the Commission as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the
United States.
|
|
|
|
|
|
Very truly yours,
|
|
|
/s/ James Snyder
|
|
|
James Snyder |
|
|
Corporate Controller
Calavo Growers, Inc. |
|
|