LL - Mama Said Knock You Out

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    Lumber Liquidators Holdings, Inc.

    (NYSE: LL)

    Prepared by:

    800 Golfview Park

    Lenoir, NC 28645

    (828) 758 6100

    www.broyhillasset.com

    December 2010

    B ROYHILL A F F I N I T Y FUND

    http://www.broyhillasset.com/http://www.broyhillasset.com/http://www.broyhillasset.com/
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    DISCLAIMER

    The analyses and conclusions of Broyhill Affinity Fund LLC (Broyhill) contained in this presentation

    are based on publicly available information including SEC filings and numerous other public sources

    that we believe to be reliable. We recognize that there may be confidential information in thepossession of the companies discussed in this presentation that could lead these companies to

    disagree with our conclusions. If we have made any errors or if any readers have additional facts or

    corrections, we welcome hearing from you. This presentation and the information contained herein is

    not a recommendation or solicitation to buy or sell any securities.

    Our purpose is to disseminate publicly available information that we believe has not been made

    readily available to the investing public but is critical to an evaluation of the company. The analyses

    provided may include certain statements, estimates, and projections prepared with respect to the

    historical and anticipated operating performance of the company. Such statements, estimates, and

    projections reflect various assumptions by Broyhill concerning anticipated results that are inherentlysubject to significant economic, competitive, and other uncertainties and contingencies and have

    been included solely for illustrative purposes. No representations, expressed or implied, are made as

    to the accuracy or completeness of such statements, estimates or projections, or with respect to any

    other materials herein.

    Assets managed by Broyhill and its affiliates have shorted common stock and purchased equity put

    options on Lumber Liquidators Holdings, Inc. (LL). Broyhill manages a fund that is in the business of

    trading buying and selling securities and financial instruments. It is possible that there will be

    developments in the future that cause Broyhill to change its position regarding LL. Broyhill may buy,

    sell, cover, or otherwise change the form of its investment in LL for any reason. Broyhill herebydisclaims any duty to provide any updates or changes to the analyses contained here including,

    without limitation, the manner or type of Broyhill investment.

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    Background

    Lumber Liquidators (LL) is a low cost provider of flooring which operates discount stores across the

    United States. They maintain this advantage by locating stores in low-rent areas (translation inferior

    locations), developing direct relationships with mills, and most importantly, sourcing about 40% of their

    total product from China. Typical stores are 6,400 to 6,600 square feet and leased for five years withrenewal options. Each store has a manager and a few associates paid a low base salary plus bonus. The

    company was founded in 1994 and went public in 2007. Tom Sullivan, founder and chairman, owns

    roughly 13% of the shares outstanding.

    Hardwood floors represent 57% of their sales with the companys flagship Bellawood product making up

    20% of net sales in 2009. LL also sells laminates (18%), moldings (13%), and bamboo/cork products

    (11%).1 Their top ten suppliers accounted for 69% of 2009 flooring purchases with 44% sourced from

    Asia, 37% from North America, 13% from South America and 6% from other locations. All foreign

    purchases are negotiated and paid for in USD. In 2009, 88% of orders went through their Virginia

    distribution center. They are expanding a new program where goods are shipped directly to stores fromChina. LLs hardwood flooring market share was roughly 10% in 2009 2 (8-9% in 2008 and 7% in 2007).3

    Da Bulls

    Bulls view LL as one of the few remaining retail growth stories as management aims to open a few dozen

    stores annually for the next several years in a roughly equal mix of new and existing markets. About half

    of the companys stores have opened in the past three years. It is easy to understand why when new

    stores are typically profitable within three months and have returned the initial cash investment within

    a year. But while a rapidly expanding store base has produced revenue expansion throughout the

    housing bust, same stores sales fell off a cliff during this period. We wonder how quickly bullishoptimism over new store growth might turn into concerns for cannibalization as comps at mature stores

    continue to deteriorate. As we discuss in detail below, we believe demand for LLs core products are set

    to decline next year as the foreclosure moratorium and expiration of homebuyer tax credits will have a

    meaningfully negative impact on existing home sales. With the street forecasting a much stronger

    outlook for home prices (we struggle to find anyone calling for a decline more than 0% - 5%), investors

    in LL shares are set up for a major disappointment.

    Wall Street claims that LLs low cost advantage provides the company with a market niche that is

    difficult to lose. Bulls point to its focused product assortment, direct sourcing and good customer

    service as core competitive advantages over big box retailers. We think the street is missing several

    key issues that are likely to present major challenges in the year ahead. First, gross margins are likely to

    come down more than expected due to rising energy and transportation costs and increasing wage

    pressures in China. Because labor is a greater percentage of the total cost for engineered wood flooring,

    increasing Chinese labor inflation would quickly put a big dent in any cost advantage assumed by the

    bulls. In addition to downward pressure on gross margins, we also anticipate upward pressure on SG&A

    due to continued difficulties with the implementation of SAP into next year. Management guidance and

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    the streets acceptance that this is a one or two quarter blip runs contrary to past experience. Last but

    certainly not least, we are shocked by investors total and complete disregard for the pending US

    International Trade Commission investigation into Multilayered Wood Flooring (MLWF) imports from

    China. At best, this investigation introduces substantial uncertainty into the business and serves as a

    distraction to managements limited time and resources. At worst, if the ITC were to set a tariff

    anywhere near the maximum level requested, we believe LLs business model and cost advantage

    would be severely challenged.

    Six Minutes of Pleasure

    Shares of LL rose 375% from a low of $7.02 in March 2009 to a high of $33.41 earlier this year. Its

    worth noting that Tom Sullivan has sold roughly five million shares since the March lows with the great

    majority of sales at prices north of $20.4

    At last weeks closing price of $23.42, the stock changed hands

    at 24x and 18x 2010 and 2011 consensus earnings expectations, respectively. Analysts are looking for

    30% earnings growth next year driven by new store openings, operating leverage, and stabilization in

    the domestic housing market. We have our doubts. Taking management at their word that MLWF only

    represents 10% - 11% of total sales, we estimate that a 50% tariff on Chinese imports would reduce next

    years earnings to $0.94, other things being equal. An earnings miss of this magnitude would likely

    result in multiple compression, as valuations of high growth retailers are inherently unstable. For

    perspective, note that LL has traded as low as 8.6x and as high as 27.6x forward earnings since the

    company went public. Even giving the company the benefit of the doubt, and maintaining the stocks

    current forward multiple, shares could easily trade down toward the $11 to $16 range based on the

    midpoint of our estimates highlighted in this report. If our estimation that LLs exposure to MLWF

    represents a much larger share of the hardwood segment is correct (our research points to anywhere

    from one half to two thirds of segment sales), the impact would be much, much greater. And a higher

    tariff (potentially north of 200 percent), when combined with greater exposure to engineered flooring

    (as we believe), could present a disaster scenario for LL shares.

    Recent Results

    At quarter end, LL was operating

    out of 213 stores in 46 states.

    Management is expecting 9 to 11

    additional openings in the current

    quarter.5 New store growth

    continues to drive top line results

    as total sales increased 4.7%

    during the quarter. Importantly,

    comparable store sales were

    down an ugly 5.7% alongside the

    expiration of an important tax

    credit for home buyers. While management blames the poor results on the implementation of SAP

    http://www.youtube.com/watch?v=MoZ4yuMJ5-4http://www.youtube.com/watch?v=MoZ4yuMJ5-4http://www.youtube.com/watch?v=MoZ4yuMJ5-4
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    during the quarter (more

    on this below), we think

    there is sufficient evidence

    to suggest bigger issues

    lurking below the surface.

    Despite earning over $20

    million year to date, the

    companys free cash flow

    has fallen more than $11

    million as LLs cash position

    has swung from $50.7

    miilion earlier this year, to $26.8M at the end of the most recent quarter.

    Inventory increased over 50% year-over-year during the quarter versus the 4.7% increase in sales. While

    management attributes the significantly increased inventory levels to the systems implementation, we

    suspect there is more to the story and estimate that inventory would have increased materially even

    excluding the impact from SAP. Our contacts in the industry have warned that sales have fallen off a

    cliff post the expiration of the home buyers tax credit. Its certainly possible that LL is only now peering

    over this cliff as the great majority of the companys floors are bought for existing homes rather than

    new construction, so a lagged effect relative to industry peers could also drive a free fall in comps. Gross

    margins declined during the quarter due to higher transportation costs, less efficient finishing costs and

    SAP implementation. We think these headwinds are likely to continue into next year, as Quantitative

    Easing predictably results in significant commodity inflation and increasing transportation costs,

    aggravated by a weaker dollar. SG&A was also higher than expected due to increased labor costs - more

    stores to staff and more overtime from SAP. Management warned investors to expect additional

    reductions in productivity in the current quarter due to the use of greater resources than expected for

    SAP implementation. Wed warn investors that these issues are likely to be a headwind through next

    year and simply represent the tip of the iceberg. We think LL has over-earned as a public company as a

    confluence of benefits propped up gross margins at unsustainably high levels. It now appears that many

    of these tailwinds (i.e. cheap sourcing, cheap fuel, cheap transportation, excess capacity, etc.) are likely

    to recede in coming quarters and should represent strong headwinds ahead.

    Sapped by SAP

    LL began implementation of SAP, a retail management system, during the third quarter. This is

    ultimately a positive for the company as it will integrate systems, increase efficiency and potentially

    reduce SG&A. But if the current quarter is any indication, investors should not expect any such benefits

    until the latter part of 2011. We expect nothing but headaches between now and then.

    Shortly after implementation, management claims to have experienced problems satisfying existing

    customer orders, distributing product to stores, and allocating resources needed to operate.

    Management estimates that reduced productivity cost an estimated $12-14 million in lost sales during

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    the quarter, and increased costs associated with inefficient product transportation and increased

    inventory reduced gross margin by 30 basis points. Importantly, LL had still not reached pre-

    implementation productivity even by the end of quarter. Capitalized costs for SAP were expected to be

    $13 million. The implementation cost $13.9 million last quarter, with another $1.5-2.5 million expected

    next quarter.6 We wouldnt be surprised by larger numbers ahead.

    LL store managers we spoke with highlighted continuing difficulties with the integration and agreed that

    it was continuing to impair their ability to address customer demand. This sentiment broadly confirms

    our findings of others in relation to SAP systems. Conversations with people familiar with SAP

    integration indicate that when a company is having this much trouble, there is likely more to come. We

    expect SAP to be a net drag on performance for the next year or so, much longer than the street

    anticipates. On the recent call, management explained that they have very ambitious plans to make

    our whole allocation and planning process more complex and we . . . just did not have the tools to do it . .

    . Having said this before, we had a lot of manual processes that are running a lot of things off of Excel

    spreadsheets.7

    Going Back to Cali

    This is not exactly confidence inspiring for a company operating over 200 stores and

    generating sales in excess of $500 million, but we imagine its typical for retail growth stories to

    outgrow the spreadsheets put in place a decade ago when managing two or three dozen stores. Once

    again, this is a long term positive for the company, but its almost impossible to imagine a smooth

    transition.WhileSAP headaches are likely to drag on for several more quarters, we believe that many of

    the difficulties experienced in the latter part of the quarter and attributed to systems integration are

    also masking a fall-off in demand from the expiration of significant housing stimulus earlier this year.

    Existing home sales and changes in home prices are the most significant determinants of demand for

    LLs products. In the section below, well examine these demand drivers more closely.

    Demand trends across the home improvement industry are largely dependent on several key variables.

    Most critical for LL is the pace of existing home sales as roughly 90% of their products are sold to people

    that have been in their home for several years and are remodeling. 8 Turnover in the housing market

    encourages renovation, which is a leading indicator of traffic to home improvement retailers. Existing

    home sales fell nearly 20% in September as the end of the homebuyer tax credit caused existing home

    sales to fall off a cliff. The expiration of this tax credit should become an increasing headwind for LL in

    2011.

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    Negative equity is a major

    problem with one in four

    mortgages underwater and

    the national loan-to-value

    rates 75% higher than the

    long term average.

    Importantly, in two of LLs

    largest markets, Florida

    and California, over 40% of

    all mortgages are

    underwater. Given the

    severity of the problem, a

    homeowners ability to

    extract equity from a home

    to purchase a new home,

    or to renovate their

    existing household, is

    largely impaired. Making matters worse, those mortgages currently close to being underwater are likely

    to get wet with a further decline in home prices. Just a few months ago, Deutsche Bank projected that

    the negative equity rate may rise to 48% in 2011. All of this is to say that the existing foreclosure issue is

    likely to get worse before it gets better greatly inhibiting the natural level of housing churn, which home

    improvement retailers have learned to depend on. If homeowners lack mobility due to negative equity

    (an issue also aggravating todays elevated structural unemployment levels), LLs store traffic should

    slow. This traffic is a powerful driver of wood flooring demand as the average new home owner spends

    an incremental $2,000 - $3,000 on improvements in the first 12-18 months of residence. 9

    After existing home sales, home

    prices are the next most important

    driver of home improvement

    demand. As home prices increase,

    consumers are more willing to

    undertake major renovation

    projects such as wood flooring.

    But in a deflating home price

    environment, few major

    renovations are undertaken.

    Continued foreclosures, high and

    stagnant unemployment,

    consumer deleveraging, and

    growing fiscal headwinds should keep pressure on home prices and slow a recovery in big-ticket home

    Dare We Say Double Dip?

    http://link.businessinsider.com/id4.3r2/THV9YCpfvLnz2I3IBc381
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    improvement purchases. As the backlog of housing inventory is likely to cause a double-dip in home

    prices, we should see further declines in LLs average ticket.

    We have yet to see any meaningful improvement in the national housing inventory overhang. The chart

    at right highlights months of supply

    of homes on the market. Currently,

    there are almost 11 months of

    supply on the market, which is near

    the highs of 2008. There are now

    over 4 million housing units on the

    market, a number which has

    accelerated throughout the year. In

    addition to the official inventory,

    there are also an estimated 6 million

    houses that are not on the market,

    but are considered shadow

    inventory. The good folks at

    Hedgeye calculate that supply of

    housing is in the top two deciles of inventory levels, and historically prices have typically fallen more

    than 15% over the following 15 months when at these levels. 10

    We believe home improvement demand is set to decline next year as the foreclosure moratorium and

    expiration of homebuyer tax credits will have a meaningfully negative impact on existing home sales.

    When considering the shadow inventory overhang alongside these factors, a further 10% - 20%

    decline in home prices from existing levels is not difficult to envision. Any growth in the industry is likely

    to be focused on smaller projects driven by more regular traffic, neither of which bode particularly well

    for LL, whose focus on high dollar renovations should result in underperformance within an already

    weak industry. With the street forecasting a much stronger outlook for home prices (we struggle to

    find anyone calling for a decline more than 0% - 5%), investors in LL shares are set up for a major

    disappointment.

    More Talk About Consumer Deleveraging11

    Beyond pure housing industry data which does not paint a pretty picture, it is important to consider the

    state of the consumer. We view changes in consumer confidence and the level of private sector credit

    for indications of consumers willingness and ability to take on debt. Declines in credit can have a

    material impact on home improvement spending as can a fall in consumer confidence. Needless to say,

    the U.S. consumer remains extremely over-indebted, with aggregate private debt to GDP now at 267%

    versus the peak level of 298% achieved back in February 2009. With debt levels as high as they are, the

    potential for further deleveraging still exceeds the worst experienced during the Great Depression.

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    So the consumers ability to take on

    additional debt is questionable at

    best. Wed argue that their

    willingness to take on additional

    debt is equally as low based upon

    the lackluster rebound

    experienced by the Conference

    Boards Consumer Confidence Index

    and this years surprising decline.

    Contrary to bullish beliefs, lower

    mortgage rates do little to spur

    incremental demand, as the

    marginal buyer has already

    refinanced, and those that havent

    already refinanced may run into

    difficulties swimming that far under

    water. Against this consumer

    backdrop, we expect comps to

    remain under pressure next year

    due to the companys high average

    ticket and declining selling prices. A

    few years ago, Todays Homeowner

    indicated that flooring replacement

    was low on consumers priority list,

    far below minor kitchen and bath

    remodels, deck additions, siding and

    window replacement, and

    additions. Wed imagine it is even

    lower today given the credit

    constraints and high price tag relative to cheaper alternatives. The U.S. consumers new fervor for

    frugality means her preference for LLs bamboo earrings . . . at least two pair12

    is clearly waning. On

    LLs recent earnings call, management confirmed our suspicions warning that average ticket indicates

    that it is a person doing one room at a time. Most store sales contacts we spoke to also indicated that

    the average spend remains lower than they ever remembered due to: less expensive products, reduced

    potential for incremental sales (peripherals, glues, sheeting, etc.) and increased push back from

    customers in terms of price. Almost all of them noted the continued preference of customers towards

    lower priced flooring products. And speaking of lower priced goods . . .

    Punked by Protectionism

    On October 21, the Coalition for American Hardwood Parity (CAHP) filed a complaint with the US

    Department of Commerce and the US International Trade Commission regarding Chinese MLWF

    http://www.youtube.com/watch?v=pdxlFcZjBvwhttp://www.youtube.com/watch?v=pdxlFcZjBvwhttp://www.youtube.com/watch?v=pdxlFcZjBvwhttp://www.youtube.com/watch?v=pdxlFcZjBvw
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    products. The complaint alleges that the Chinese are unfairly subsidizing the product, dumping below

    cost on the US market, and stealing intellectual property from domestic producers. On top of this, the

    petition cites the low cost of labor and low cost of raw material sourced from illegally logged lumber as

    unfair advantages. For the first six months of 2009 and 2010 value per square foot were $1.50 and $1.49

    from China, less than half the cost of domestic products which carried a value per square foot of $3.18

    and $2.99 over the comparable periods.13

    CAHP supports our view that improvements in the wood floor market in late 2009 and early 2010 were

    the direct result of the homebuyer tax credit, which was applicable from Jan 1, 2009 to April 30, 2010. If

    a contract was signed prior to April 30 and closed before Sep 30, it also qualified, which would help

    explain the lagged decline in LL comps relative to already falling existing home sales. Obviously, CAHP is

    upset that the massive stimulus intended to benefit American consumers and industry did not have a

    meaningful impact on domestic producers. We dont blame them, although we recognize that being

    rightfully angry probably doesnt warrant slapping a massive tariff on your competitors. More

    importantly, we believe the evidence clearly points in that direction, regardless of domestic emotions.

    Chinas share of the US market increased from 10% to 27% between 2002 and 2007 as US imports of

    Chinese MLWF increased by 76% over this period, and Chinas total wood flooring production increased

    by 64%. Chinas total MLWF output increased by a further 49% from 2008 to 2009 to 1.27 billion square

    feet. US MLWF market share held by Chinese imports hit a peak of 34.7% in June 2010. Due to

    underselling by Chinese imports, domestic producers have curtailed product lines (or eliminated them

    altogether) leading to plant closures and employment reductions. The petition requests a 242% tariff be

    placed on multi-layer wood flooring from China for these reasons and notes that even if the housing

    market recovers, the recovery will likely be dominated by cheap imports. An initial hearing in early

    November determined that the United States International Trade Commission will investigate the issue

    and potentially put a tariff in place on Chinese MLWF imports. 14

    We expect the ITC to determine if

    theres enough evidence to hold a preliminary hearing this Friday, December 3 rd. Given the extensive

    evidence weve reviewed, we are confident this will pass. At the end of the preliminary phase, which we

    understand will conclude during the second quarter, the ITC will implement a preliminary tariff if there is

    enough evidence to support it. Investors should mark their calendars accordingly, as these are important

    dates. We have yet to find a single sell side research piece that properly considers these hearings (the

    first time it was even mentioned was a few sentences in a report this week) and management has yet to

    say a word about them publically despite filing an earnings release and hosting a conference call since

    the initial hearings, where an army of LL representatives were present. Hmmmmmm.

    Chinese MILF MLWF

    MLWF has a more advantageous raw material yield when compared with solid wood flooring (20-30% of

    the log ends up in the final product for solid wood flooring compared to 70-80% for MLWF).15 Therefore,

    labor is a greater percentage of the total cost for engineered wood flooring, providing China with an

    advantage over domestic producers. The increase in the volume of imports has been a result of home

    centers and direct distribution centers such as Home Depot, Lowes, and Lumber Liquidators. This growth

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    has come at the expense of smaller distributors. LL is estimated to account for 10% of the total US wood

    flooring market, up from 5.1% in 2006.16

    At a September conference, LL noted that 40% of their product

    is sourced from China. We estimate that a good portion of these imports are engineered flooring, and as

    such, it is curious that management has yet to even mention the potential for such a large increase in

    costs. Perhaps they dont believe it is significant or a realistic threat to their business model. But while

    management downplays the potential impact of a tariff, industry insiders weve consulted put the odds

    of a 50% (or higher) tariff at 70%, 75% (or higher) tariff at 50% and a tariff in excess of 100% at a 30%

    probability. If assigned at the conclusion of the preliminary hearings (likely sometime in Q2-11), an

    escrow tariff would be charged immediately and any difference between the final tariff and the

    preliminary tariff would be collected retroactively after a final decision was concluded.

    2011 EPS Estimates

    Tariff

    20.0% 50.0% 70.0% 100.0%

    MLWFas%ofTota

    l

    Hardwood

    20% 1.14 0.94 0.81 0.6230% 1.08 0.78 0.58 0.29

    40% 1.01 0.62 0.35 (0.04)

    50% 0.94 0.45 0.12 (0.37)

    60% 0.88 0.29 (0.11) (0.70)

    70% 0.81 0.12 (0.34) (1.03)

    In 2009, Lumber Liquidators derived 57% of its revenue from solid and multi-layer wood flooring

    combined. While management will not publically disclose what percentage of this is MLWF in company

    filings, checks with stores and industry experts reveal that it is the majority of their wood sales.

    Curiously, most of the research we have conducted produced very different answers than those verbally

    suggested by management, who claim that engineered flooring only represents 10% - 11% of total

    sales17

    (although even using these lower figures, the potential margin impact from a tariff on Chinese

    imports would be substantial as shown in the above matrix). A company contact in customer care

    suggested it was a roughly even split between hardwood and MLWF. The 2011 Edition of The U.S. Floor

    Reportindicates that MLWF is closer to two thirds of LLs wood flooring segment. We also thought it was

    interesting that not a single sales person we spoke to tried to sell us solid hardwood products, even

    when we specifically asked about them. Most store contacts we spoke with indicated that they have

    received direct instructions from their managers to continue to push engineered products.

    LLs Ears Should beJingling Baby

    Importantly, we believe that the vast majority of Lumber Liquidators MLWF is sourced from China. A

    salesman at the LL call center, after checking with the relevant department, informed us that 80% of

    their MLWF was sourced from China. They followed up on this by checking with one of LLs buyers, who

    reported that only the Bellawood line (20% of 2009 net sales) is sourced domestically. Another manager,

    when asked if they carried any products not sourced from China, replied that they carried many

    http://www.youtube.com/watch?v=xU5lQsV0L6shttp://www.youtube.com/watch?v=xU5lQsV0L6shttp://www.youtube.com/watch?v=xU5lQsV0L6shttp://www.youtube.com/watch?v=xU5lQsV0L6s
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    products by Schn. But after confirming with a more knowledgeable store contact, he replied that

    despite the Swedish name, these products were also sourced from China. He concluded by saying,

    Nope, never mind, everythings from China. By far our favorite response came when we inquired

    about domestically sourced engineered flooring. A store manager told us to go to the nearest hardware

    store and buy an ax. Solid hickory handle - 100% US. Then go to the nearest forest and cut down a tree.

    Next, go buy a band saw and mill it yourself. Perhaps a bit of an exaggeration, but it makes our point

    nicely.

    The magnitude of any tariff is unknown (well learn more by March 2011) but the effect that it will have

    on Lumber Liquidators is clear. If this petition is passed in any form, we believe it would kick off a

    scramble for cheap supply causing costs to surge before substantial product can be re-sourced or

    mitigated in any way. In the event of a more extreme tariff, producers would predictably attempt to re-

    source away from China. One flooring executive even commented in the ITC hearing that he expected to

    be on a plane the day

    after Thanksgiving to

    Indonesia.18 But due to

    the insignificant capacity

    in other inexpensive

    locations, this is not a

    viable option on any

    significant scale in the

    short term. While

    Indonesia is the cheapest

    alternative, it represents

    roughly a tenth of

    Chinese capacity and our

    sources tell us much of it

    is illegally sourced. Those

    unfamiliar with the Lacey

    Act may want to quickly acquaint themselves with illegal logging practices as an important addition to

    the act calls on vendors to be accountable for documenting the path of a product from harvest to sale.

    According to an industry report by Catalina Research, only 18.8 million square feet of MLWF is imported

    to the US from countries with an average cost within 100% of China. This compares to 71.2 million

    square feet imported from China and 98.6 million square feet of total US imports. 19

    Critically, we believe

    that re-sourcing any significant portion of the Chinese production will result in greater demand for lower

    capacity locations, ultimately increasing the price of imports anyway. The net result in any scenario is a

    major impact on costs and margins, neither of which is being discussed by the street or by LL

    management. We wonder why Armstrong felt it was material enough to include the language below in

    their latest filing despite having a much smaller impact to their business than LL in our estimation

    (emphasis added):

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    On October 21, 2010, a coalition of U.S. producers of multilayered wood flooring (not including

    Armstrong) filed antidumping (AD) and countervailing duty (CVD) petitions regarding multilayered

    hardwood flooring from China. The AD petition requests that the Department of Commerce impose

    duties of up to 242% on imports of multilayered hardwood flooring, which it claims is needed to offset

    unfair pricing from Chinese imports that injure the U.S. industry. The CVD petition requests an

    unspecified level of duties be imposed on importers to offset alleged unfair subsidies provided by the

    Chinese government (such as the undervaluation of the Chinese currency, various tax benefits for

    foreign-invested enterprises, VAT and tariff exemptions on imported equipment, and electricity being

    provided at artificially low rates).

    Armstrong World Industries, Inc. is a domestic producer of multilayered wood flooring. We also import

    multilayered wood flooring from suppliers in China and we have a plant in China that manufactures

    multilayered wood flooring for export to the U.S. Armstrong is specifically mentioned in the AD and CVD

    petitions as an importer. Under the U.S. AD and CVD laws, a U.S. importer may be responsible for the

    payment of any antidumping and countervailing duties. The Department of Commerce and the

    International Trade Commission have only just commenced their investigations and the outcome of the

    cases are uncertain. As a result, at this time we cannot say whether an adverse ruling is probable or

    estimable. However, if such an adverse ruling were to be issued,Armstrong could be subject to duties on

    multilayered hardwood flooring imported from China, and it is possible such duties could be

    material20

    .

    Score One for Consensus

    While the street remains willfully blind to the potential business-busting tariff on Chinese imports, we

    have noticed more than a few analysts correctly mentioned sourcing as a risk to LL shares going

    forward. Compliments of our beloved Fed, most domestic retailers can now look forward to spiraling

    commodity costs in the year ahead. This factor, which should be familiar since they faced a similar

    dynamic in early 2008, is compounded by a weaker dollar and labor inflation in China. All of which

    should keep steady downward pressure on gross margins. And while most goods sold in home

    improvement stores have a relatively small labor cost, engineered flooring is much more labor intensive,

    which of course, explains why most of it is imported from China in the first place. Once again, this

    negative gross margin cocktail does not bode well for the LL profit outlook. Labor costs have already

    begun to increase as a percentage of net sales, perhaps signaling inefficiencies and diseconomies of

    scale.

    Dont Wake the Beast

    The home improvement industry remains largely fragmented despite the dominance of two big box

    retailers, Home Depot and Lowes. Bulls claim that there is plenty of room for LL to grab share. Wed

    prefer not to agitate the sleeping giant in the market as these boys bring product selection and

    efficiency that is impossible for the niche players to match. Home Depot and Lowes have built

    tremendous brand franchises with powerful logistical capabilities and strong vendor relationships. Wed

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    rather not get in the ring with the big boys, but it seems that LL has gotten their attention. In the first

    quarter, Lowes took on additional flooring inventory with the aim of taking share in this category.21

    We

    would not want to be seen as an emerging threat to these industry powerhouses. Come to think of it,

    given Home Depots lower ticket products, rigorous cost controls, substantial free cash flow generation

    and 3% dividend yield, HD/LL appears to offer compelling risk/reward for a pair trade.

    Fanfare for the Low Cost Provider

    Customer reviews on the companys website are wonderful. What we found more interesting was that

    when searching for the companys website, the second auto-fill option in the Google search bar is

    Lumber Liquidators Complaints. Weve highlighted just a few of these mostly for entertainment

    purposes. The general idea is that you get what you pay for both in product quality and customer

    service.

    Shame on Bob Vila for representing this company.

    Lumber Liquidators should change their name to "Customer Liquidators." The service is the worst I have

    ever encountered! Stay away from these people; they should not be in business.

    They are by far the worst company I have ever dealt with in my 23 years in the trade. Deceitful, poor

    quality and the WORST CUSTOMER SERVICE.

    Bought Supreme Bamboo with 15 yr finish warranty. The finish has worn off in 8 months. Sought the

    help of customer care to settle a claim. It literally took 3 months for them to resolve the issue and finally

    send a letter denying the claim. Lumber Liquidators was the worst customer experience I have ever had -

    and the ONLY online vendor that has prompted me to submit this type of e-review. Bottom line, buy a

    nicer wood from another vendor if you want long lasting beauty and quality. Their price was great, but

    now I have a worn scratched, dented floor that will have to be removed and replaced much earlier than

    I'd ever imagined.

    When I tried to pick up an order from one of the stores, the store manager persuaded me to submit a

    new order because "they were upgrading their software and couldn't retrieve my order information,

    saying I could easily cancel the internet order. However, one month passed, 4-5 phone calls have been

    made, and still they haven't refunded the credit back. Horrible customer service.

    We ordered 23 boxes of product, which came from 2 different mills with production years stamped on

    the end of the boxes between 2006 and 2010. The tongue and groove did not interlock and the color

    variation between the product (natural birch) in the various product runs were not even close. We

    purchased a premium Bellawood product - not a cheap or close-out product.

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    What If Were Wrong?

    While we have long believed that interest rates will remain lower for longer than current consensus

    expectations, weve been wrong often enough to know that well likely be wrong quite often in the

    future as well. In this particular case, if we are wrong on rates, we should be very right on LL as the real

    negative demand shock would come in the form of a spike in rates. With nearly $1 trillion of option

    ARMs and Alt-A mortgages resetting by 2012, if Bernanke is successful in engineering inflation, and

    these rates reset higher alongside a rising CPI, it is game over for homeowners, who would default en

    masse. Not exactly a happy ending for home improvement demand.

    We recognize that the current investigation may not materialize into an import tariff and that the

    potential impact of any tariff may be negated by LLs ability to pass costs through to the consumer. But

    we wonder how a low cost provider maintains its competitive advantage when costs increase. Aside

    from a dramatic recovery in the domestic housing market, it is difficult to envision material upside for

    shares at todays valuation. Such a magical rebound would clearly fly in the face of historical evidence.

    As Carmen Reinhardt detailed in a recent NBER Working Paper, about 90% of historical observations

    examined surrounding a financial shock showed real house prices below their pre-crisis levels with

    cumulative declines as large as 55% and median real estate prices 15% - 20% lower, a full decade later.

    We wouldnt bet the ranch on a major resurgence of the home as an ATM machine in America.

    Perhaps expansion into international markets will provide the upside bulls are hoping for? Management

    recently pushed back its planned expansion into Canada from the fourth quarter into 2011 as it struggles

    with the implementation of SAP. We think this is a good idea and might suggest shelving any northern

    expansion at least until some of the air is let out of that bubble. The Canadian housing market looks

    eerily similar to another commodity-related housing market we are quite familiar with. While

    residential real estate prices at home are well off their highs, Canadian home owners have enjoyed a

    continued surge after a brief blip lower in 2008. Historical data clearly indicates that the ratio of home

    prices to income has always fluctuated around a stagnant long term average. The reason is that income

    acts as an anchor limiting the price homeowners are able to pay, and has always pulled prices back to

    earth in every instance. It is only a

    matter of time. The average family can

    afford a home about 3.5 times their

    income. In 2005-2006, new homes in

    the U.S. were selling for well over 5

    times median income while other real

    estate bubbles have grown to 6 or 7.5

    times. Canadian real estate is at 6.5

    times family income today nearly

    double the price it should be. Not

    exactly a market wed consider ripe for

    expansion.

    http://www.kansascityfed.org/publicat/sympos/2010/2010-08-17-reinhart.pdfhttp://www.kansascityfed.org/publicat/sympos/2010/2010-08-17-reinhart.pdfhttp://www.kansascityfed.org/publicat/sympos/2010/2010-08-17-reinhart.pdfhttp://www.viewfromtheblueridge.com/2010/07/27/who-can-it-be-now/http://www.viewfromtheblueridge.com/2010/07/27/who-can-it-be-now/http://www.viewfromtheblueridge.com/2010/07/27/who-can-it-be-now/http://www.kansascityfed.org/publicat/sympos/2010/2010-08-17-reinhart.pdf
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    Endnotes

    1Lumber Liquidators 2009 10-K

    2Catalina Research, Petition for the Imposition of Antidumping and Countervailing Duties: Multilayered Wood

    Flooring from the Peoples Republic of China, Coalition for American Hardwood Parity3

    Lumber Liquidators 2009 10-K4 FinViz.com, LL Insider Trading5

    Lumber Liquidators Q3-10 10Q6

    Lumber Liquidators Q3-10 10Q7

    Thomson Reuters, LL Q3-10 Earnings Call Transcript8

    Lumber Liquidators 2009 10-K9

    ISI 2011 Home Improvement Outlook10

    Hedgeye Risk Management11

    Broyhill Asset Management, The Great flation Debate12

    James LL Cool J Smith, Around the Way Girl, Mama Said Knock You Out199013

    Catalina Research, Petition for the Imposition of Antidumping and Countervailing Duties: Multilayered Wood

    Flooring from the Peoples Republic of China, Coalition for American Hardwood Parity14

    Petition for the Imposition of Antidumping and Countervailing Duties: Multilayered Wood Flooring from the

    Peoples Republic of China, Coalition for American Hardwood Parity15Petition for the Imposition of Antidumping and Countervailing Duties: Multilayered Wood Flooring from the

    Peoples Republic of China, Coalition for American Hardwood Parity16

    Catalina Research, Petition for the Imposition of Antidumping and Countervailing Duties: Multilayered Wood

    Flooring from the Peoples Republic of China, Coalition for American Hardwood Parity17

    November 23, 2010 Call with LL Management18

    ITC Hearing Transcript19

    Catalina Research, Petition for the Imposition of Antidumping and Countervailing Duties: Multilayered Wood

    Flooring from the Peoples Republic of China, Coalition for American Hardwood Parity20

    Armstrong World Industries Q3-10 10Q21

    Thomson Reuters, LOW Q2-10 Earnings Call Transcript