July 15, 2020
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, NE
Washington, D.C. 20549
Attention: James Giugliano and Rufus Decker
| Re: | MarineMax, Inc. |
Form 10-K for the Fiscal Year Ended September 30, 2019 |
Filed December 3, 2019 |
Form 8-K Filed October 29, 2019 |
File No. 001-14173 |
Dear Mr. Giugliano and Mr. Decker:
Per our previous conversations with the Securities and Exchange Commission, for the fiscal year ended September 30, 2019, we have performed an impairment analysis by retail location asset group, and concluded that the results from the analysis by retail location asset group do not materially differ from the analysis by regional asset group. We believe no impairment of long-lived assets existed as of September 30, 2019. If, during future periods, a material difference arises in the impairment analysis by retail location asset group versus regional asset group, we will revisit our accounting policy and, if needed, discuss our accounting policy with the Securities and Exchange Commission Office of the Chief Accountant.
If you have any questions or comments regarding this response or require any additional information, please do not hesitate to contact me at (727) 531-1700.
Respectfully submitted,
MarineMax, Inc. | ||
| By: | /s/ Michael H. McLamb | |
| Michael H. McLamb | ||
| Chief Financial Officer | ||
| CC: | W. Brett McGill, Chief Executive Officer and President, MarineMax, Inc. |
Robert J. Grammig, Esq., Holland & Knight LLP
Joseph F. Cannella, Partner, KPMG LLP
