United States securities and exchange commission logo
January 5, 2021
Mick Beekhuisen
Chief Financial Officer
CAMPBELL SOUP CO
1 Campbell Place
Camden, NJ 08103-1799
Re: CAMPBELL SOUP CO
Form 10-K for
Fiscal Year Ended August 2, 2020
Filed September 24,
2020
File No. 1-03822
Dear Mr. Beekhuisen:
We have reviewed your filing 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.
Annual Report on Form 10-K for the fiscal year ended August 2, 2020
filed September 24, 2020
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Significant Accounting Estimates
Goodwill and intangible assets, page 36
1. We note your disclosure
which states that all of your reporting units had an excess fair
value "well over" the
carrying value. We note elsewhere in your document that the
acquisition of
Snyder's-Lance resulted in a significant majority of your goodwill and
trademark intangible
balances. Also in your document, we note that in both 2018 and
2019, the acquisition
of Snyder's-Lance has contributed losses to your earnings from
continuing operations.
As such, please address the following:
Revise your
disclosure to state if true, that all your reporting unit fair values
"significantly
exceeded" their carrying value.
To the extent any
reporting unit fair value does not significantly exceed fair value,
identify the
reporting unit and disclose the percentage of excess fair value over
Mick Beekhuisen
CAMPBELL SOUP CO
January 5, 2021
Page 2
carrying value.
Provide expanded disclosure of your methods used to determine
fair value of your
reporting units as well as critical assumptions, including
discount rates, terminal
value growth rates and any other key assumptions.
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 Kevin Stertzel at (202) 551-3723 with questions regarding
these
comments or John Cash at (202) 551-3768 with any other questions.
FirstName LastNameMick Beekhuisen Sincerely,
Comapany NameCAMPBELL SOUP CO
Division of
Corporation Finance
January 5, 2021 Page 2 Office of
Manufacturing
FirstName LastName