[COLUMBIA SPORTSWEAR LETTERHEAD]
September 24, 2008
Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 3561
Washington, D.C. 20549
Attention: John Reynolds, Assistant Director
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Re: |
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Columbia Sportswear Company
Form 10-K for fiscal year ended December 31, 2007
Filed February 28, 2008
File No. 000-23939 |
Dear Mr. Reynolds:
Columbia Sportswear Company submits this letter in response to your telephone call with Richelle
Luther, our Deputy General Counsel, on September 5, 2008, concerning our letter to you dated July
30, 2008 responding to comments from the Staff of the Securities and Exchange Commission contained
in a letter to us dated June 13, 2008 regarding our definitive proxy statement on Schedule 14A
filed by us on April 4, 2008. In response to comment 2 of the comment letter and your follow-up
telephone call, we supplementally confirm that, in future filings, we will disclose the specific
company performance targets set by the compensation committee of our board of directors for each of
the following components of our compensation program for named executive officers:
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annual, short-term cash incentive compensation, and |
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long-term, performance-based restricted stock units. |
The specific company performance target required for vesting of any award of performance-based
restricted stock units will only be disclosed after the relevant three-year performance period has
been completed.
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If you have any questions regarding this letter, please feel free to call me directly at (503)
985-4305.
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Sincerely,
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/s/ Peter J. Bragdon |
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Peter J. Bragdon |
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Vice President and General Counsel |
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cc: |
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Bryan Timm
John R. Thomas
Edwin S. Kim, SEC |