NASHUA CORPORATION
11 Trafalgar Square, Second Floor
Nashua, New Hampshire 03063
June 10, 2005
Via Electronic Submission
United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W., Stop 4-5
Washington, DC 20549-0405
| Attention: | H. Roger Schwall | |
| Assistant Director |
| Re: | Nashua Corporation | |
| File No. 1-05492 | ||
| Form 10-K for the Fiscal Year Ended December 31, 2004 |
Ladies and Gentlemen:
On behalf of Nashua Corporation (“Nashua” or the “Company”), this letter is submitted in response to discussions with Jonathan Duersch of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the letter dated April 18, 2005 (the “SEC Comment Letter”) from H. Roger Schwall to John L. Patenaude, Chief Financial Officer of Nashua and Nashua’s letter dated April 29, 2005 in response to the SEC Comment Letter.
As requested by Mr. Duersch in our discussions regarding Nashua’s response to comment three in the SEC Comment Letter, set forth below are roll forwards of potential loss contingencies for fiscal years 2004, 2003 and 2002.
| Reserve Balance | Reserve Balance | |||||||||||||||
| 2004 Activity: | December 31, 2003 | Increase | (Payment) | December 31, 2004 | ||||||||||||
| (in thousands) | ||||||||||||||||
| Postretirement Health Benefits | $ | 1,599 | — | — | $ | 1,599 | ||||||||||
| Environmental Reserve | 652 | — | (267 | ) | 385 | |||||||||||
| Edward G. Krasnecki Litigation | — | — | — | — | ||||||||||||
| Total Contingency Reserves | $ | 2,251 | — | $ | (267 | ) | $ | 1,984 | ||||||||
Mr. H. Roger Schwall
June 10, 2005
Page 2
| Reserve Balance | Increase/ | Reserve Balance | ||||||||||||||
| 2003 Activity: | December 31, 2002 | (Decrease) | (Payment) | December 31, 2003 | ||||||||||||
| (in thousands) | ||||||||||||||||
| Postretirement Health Benefits | $ | — | $ | 1,599 | — | $ | 1,599 | |||||||||
| Environmental Reserve | 802 | 174 | (324 | ) | 652 | |||||||||||
| Edward G. Krasnecki Litigation | 140 | (13 | ) | (127 | ) | — | ||||||||||
| Total Contingency Reserves | $ | 942 | $ | 1,760 | $ | (451 | ) | $ | 2,251 | |||||||
| Reserve Balance | Reserve Balance | |||||||||||||||
| 2002 Activity: | December 31, 2001 | Increase | (Payment) | December 31, 2002 | ||||||||||||
| (in thousands) | ||||||||||||||||
| Postretirement Health Benefits | — | — | — | — | ||||||||||||
| Environmental Reserve | 1,067 | 85 | (350 | ) | 802 | |||||||||||
| Edward G. Krasnecki Litigation | — | 140 | — | 140 | ||||||||||||
| Total Contingency Reserves | $ | 1,067 | $ | 225 | $ | (350 | ) | $ | 942 | |||||||
The postretirement health benefits contingency listed in the tables set forth above relates only to the contingency resulting from Nashua’s elimination of postretirement benefits to union employees located in New Hampshire in December 2002. Nashua’s reserve for postretirement benefits that was included in long-term liabilities in Nashua’s consolidated balance sheets as of December 31, 2004, 2003 and 2002 included all postretirement benefits. The calculations for the amounts of the reserves were performed by Nashua’s actuarial consultant, Aon Corporation. Additionally, the amounts of Nashua’s environmental reserve listed in the tables set forth above are calculated by Nashua based on information from its third-party environmental consultant, Haley & Aldrich, Inc.
If you require additional information, please telephone the undersigned at (603) 880-2145.
Very truly yours,
/s/ John L. Patenaude
John L. Patenaude
Vice President-Finance, Chief
Financial Officer and Treasurer
| cc: | Mr. Andrew Albert | |
| Philip P. Rossetti, Esq. |