Retail & Restaurants
25 SEC staff comments and 33 disclosure examples from companies in this industry.
SIC codes included: 5990 Retail-Retail Stores, NEC, 5961 Retail-Catalog & Mail-Order Houses, 5812 Retail-Eating Places, 5500 Retail-Auto Dealers & Gasoline Stations, 5900 Retail-Miscellaneous Retail, 5600 Retail-Apparel & Accessory Stores, 5531 Retail-Auto & Home Supply Stores, 5200 Retail-Building Materials, Hardware, Garden Supply
Disclosure examples by topic
Retail & Restaurants: Liquidity & capital resources (MD&A)4 examplesRetail & Restaurants: Cybersecurity (Item 1C)3 examplesRetail & Restaurants: Pay versus performance3 examplesRetail & Restaurants: Income tax disclosures (ASU 2023-09)3 examplesRetail & Restaurants: Inventory (ASC 330)2 examplesRetail & Restaurants: Contingencies & legal proceedings (ASC 450)2 examplesRetail & Restaurants: Supplier finance programs (ASU 2022-04)2 examplesRetail & Restaurants: Earnings per share (ASC 260)2 examplesRetail & Restaurants: Goodwill impairment testing2 examplesRetail & Restaurants: Derivatives & hedging (ASC 815)1 exampleRetail & Restaurants: Segment reporting (ASU 2023-07)1 exampleRetail & Restaurants: Climate & GHG disclosures1 exampleRetail & Restaurants: Expense disaggregation (ASU 2024-03)1 exampleRetail & Restaurants: Insider trading policies (Item 408(b))1 exampleRetail & Restaurants: Key performance indicators & metrics1 exampleRetail & Restaurants: Leases (ASC 842)1 exampleRetail & Restaurants: Debt & covenant compliance1 exampleRetail & Restaurants: Recently issued standards not yet adopted (SAB 74)1 exampleRetail & Restaurants: Related party transactions (ASC 850)1 example
What the SEC staff asked companies in this industry
Non-GAAP: Reconciliation & Usefulness (11)MD&A: Results & Known Trends (7)KPIs, Metrics & Earnings Calls (6)Segment Reporting (ASC 280) (5)Non-GAAP: Adjustments & Labels (4)Earnings per Share (ASC 260) (4)Statement of Cash Flows (ASC 230) (3)Liquidity & Capital Resources (2)Goodwill & Asset Impairment (2)Fair Value & Investments (2)Exhibits, Certifications & Signatures (2)Business Combinations & Significance (1)
Live Oak Acquisition Corp. V (LOKV, LOKVU, LOKVW) · 2026-04-24 · Form 10-K for Fiscal Year Ended December 31, 2025 Form 8-K Furnished March 31, 2026 · Comment 1 · Why Teamshares matters, page 19 Responded
Staff comment: You disclose $24 million EBITDA, a non-GAAP measure, on slide 19. Please revise to provide the disclosures required by Item 100(a) of Regulation G, including a reconciliation of this non-GAAP measure to the most directly comparable GAAP measure per Item 100(a)(2). letter →
Company response: The Company respectfully acknowledges the Staff’s comment and is furnishing a copy of the Updated Teamshares Presentation to the Commission as Exhibit 99.1 to the Amended Current Report on Form 8-K intended to be responsive to the Staff’s comment. response letter →
Live Oak Acquisition Corp. V (LOKV, LOKVU, LOKVW) · 2026-04-24 · Form 10-K for Fiscal Year Ended December 31, 2025 Form 8-K Furnished March 31, 2026 · Comment 2 · Historical Financial Results and Reconciliation of Non-GAAP Measures, page 81 Responded
Staff comment: Please remove all references to the non-GAAP measure consolidated Operating EBITDA and associated amounts, including measures the computation of which are based on this measure, such as Pro Forma Operating EBITDA and Return on Equity, since the Corporate Expenses adjustment appears to exclude normal, recurring, cash operating expenses. Refer to Questions 100.01 and 104.04 of the Non-GAAP Financial Measures Corporation Finance Interpretations. letter →
Company response: The Company respectfully acknowledges the Staff’s comment and is furnishing a copy of the Updated Teamshares Presentation to the Commission as Exhibit 99.1 to the Amended Current Report. The Updated Teamshares Presentation has been revised to remove references to consolidated Operating EBITDA and associated amounts and measures the computation of which are based on or derived from such metric, including Pro Forma Operating EBITDA and Return on Equity . * * * 2 We thank you for your review of the foregoing and the Form 8-K/A and Exhibit 99.1. Should you have any questions or require any additional information, please do not hesitate to contact our legal counsel, Meredith Laitner, Esq., of… response letter →
Boqii Holding Ltd (BQ) · 2026-03-06 · Form 20-F for the Fiscal Year Ended March 31, 2025 · Comment 1 · 29. Subsequent Events, page F-55 Agreed to revise
Staff comment: We note you implemented a reverse stock split in July 2025. It does not appear that your audited financial statements and related notes have been revised to reflect the split. Further, we note the announcement of fiscal 2026 first half unaudited financial results included in Form 6-K filed January 5, 2026 does not present prior-period financial information based on the new number of shares. Please tell us your consideration of retroactively adjusting all periods presented to reflect the reverse stock split in accordance with ASC 260-10-55-12 and SAB Topic 4:C. letter →
Company response: In response to the Staff’s comment, we have revised our financial statements and related notes as well as other relevant disclosures to reflect the split in the Amendment. We thank you for your review of the foregoing and Form 20-F. If you have further comments, please feel free to contact to our counsel, Wei Wang, Esq. at wwang@egsllp.com or by telephone at (212) 370-1300. response letter →
COSTCO WHOLESALE CORP /NEW (COST) · 2026-03-04 · Costco Wholesale Corporation Form 10-K for Fiscal Year Ended August 31, 2025 · Comment 1 · Cash Flows from Operating Activities, page 29 Agreed to revise
Staff comment: Please provide a period to period comparative analysis and discussion of changes in cash flows from operating activities, including changes in working capital components, in your annual and interim period reports. In doing so, explain the underlying business reasons and implications of material changes between periods to provide investors with an understanding of variability and potential trends in cash flows. Ensure your discussion and analysis is not merely a recitation of changes evident from the consolidated statements of cash flows. Refer to Item 303(a) and (b) of Regulation S-K and SEC Release No. 33-8350. letter →
Company response: We respectfully acknowledge the Staff’s comments and will expand our disclosures to include a comparative analysis and discussion of changes in cash flows from operating activities in future filings. The following is an example of the future disclosure: Cash Flows from Operating Activities Our cash flow provided by operations is primarily from net sales and membership fees. Cash flow used in operations generally consists of payments to merchandise suppliers, warehouse operating costs, including wages and employee benefits, utilities, credit and debit card processing fees, and operating leases. Cash used in operations also includes payments for income taxes. Changes in our net investment in… response letter →
COSTCO WHOLESALE CORP /NEW (COST) · 2026-03-04 · Costco Wholesale Corporation Form 10-K for Fiscal Year Ended August 31, 2025 · Comment 2 · Note 11 - Segment Reporting, page 62 Agreed to revise
Staff comment: You disclose the CODM utilizes operating income in evaluating performance and allocating resources but not how the measure is used for these purposes. Refer to ASC 280-10-50-29(f) and ASC 280-10-55-47(bb). Please revise as appropriate. letter →
Company response: We will revise our disclosure in our future filings to include how the CODM utilizes operating income as described below: The CODM uses the metrics outlined in the table below, along with internal management reports, to evaluate performance, monitor actual results versus budget and prior year results, and make strategic and operational resource allocation decisions. Please contact me response letter →
SPORTSMAN'S WAREHOUSE HOLDINGS, INC. (SPWH) · 2026-01-27 · Form 10-K for Fiscal Year Ended February 1, 2025 · Comment 1 · Valuation of Long-Lived Assets, page 55 Agreed to revise
Staff comment: Please revise to specify the fiscal periods that you have performed an impairment assessment. In addition, clarify if the assessment at the lowest levels for which there are identifiable cash flows that are independent of other groups of assets, is the individual store level. letter →
Company response: The Company acknowledges the Staff’s comment and, in future 10-K filings, will revise its disclosure to specify the fiscal periods during which impairment assessments of long-lived assets were performed. The Company will also clarify that impairment assessments are conducted at the individual store level, which represents the lowest level for which identifiable cash flows are largely independent of other asset groups. **** response letter →
Titan Machinery Inc. (TITN) · 2026-01-27 · Form 10-K for Fiscal Year Ended January 31, 2025 · Comment 1 · Goodwill, page 39 Agreed to revise
Staff comment: Please provide information for investors to assess the probability of future goodwill impairment charges. For example, please disclose whether your reporting units are at risk of failing the quantitative impairment test or that the fair value is substantially in excess of carrying value and is not at risk of failing. If a reporting unit is at risk of failing, you should disclose: • the percentage by which fair value exceeded carrying value at the date of the most recent test; • a more detailed description of the methods and key assumptions used and how the key assumptions were determined; • a discussion of the degree of uncertainty associated with the assumptions; and • a description of… letter →
Company response: We acknowledge the Staff’s comment. In response thereto, we advise the Staff that in our presentation in future filings, commencing with the next 10-K filing, we will disclose if the fair value of a reporting unit substantially exceeds carrying value and is not at risk of failing, or if the fair value of a reporting unit does not substantially exceed the carrying value of the reporting unit, we will include the following disclosures: • the percentage by which fair value exceeded carrying value at the date of the most recent test; • a more detailed description of the methods and key assumptions used and how the key assumptions were determined; • a discussion of the degree of uncertainty… response letter →
Childrens Place, Inc. (PLCE) · 2026-01-27 · The Children's Place, Inc. Form 10-K for the Fifty-Two Weeks Ended February 1, 2025 Form 8-K filed April 11, 2025 Form 1 · Comment 1 · Results of Operations, page 37 Agreed to revise
Staff comment: You discuss adjusted selling, general and administrative expenses and adjusted operating income leveraged basis points and percentages of net sales without presenting or discussing the most directly comparable GAAP measure with equal or greater prominence. Please revise future disclosures to comply with Item 10(e)(1)(i)(A) of Regulation S-K or explain why a revision is not necessary. Refer to Question 102.10(a) of the Staff’s Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. letter →
Company response: We acknowledge the Staff’s comment and will revise future disclosures to comply with Item 10(e)(1)(i)(A) of Regulation S-K by presenting or discussing the most directly comparable GAAP measure with equal or greater prominence. response letter →
Childrens Place, Inc. (PLCE) · 2026-01-27 · The Children's Place, Inc. Form 10-K for the Fifty-Two Weeks Ended February 1, 2025 Form 8-K filed April 11, 2025 Form 1 · Comment 2 · Non-GAAP Reconciliation, page 37 Agreed to revise
Staff comment: We note numerous adjustments to your non-GAAP measures in Fiscal 2024. Please tell us your consideration of providing reconciliations in tabular form for clarity. Refer to Item 10(e)(1)(i)(B) of Regulation S-K. letter →
Company response: We acknowledge the Staff’s comment and have reviewed Item 10(e)(1)(i)(B) of Regulation S-K, which requires a reconciliation (by schedule or other clearly understandable method) of the differences between the non-GAAP financial measure disclosed or released with the most directly comparable financial measure calculated and presented in accordance with GAAP. The Company provides its reconciliation of GAAP to non-GAAP financial measures in narrative form as it believes it is an understandable method and is helpful to the reader to review these adjustments in conjunction with the description of the variances for period-over-period changes in GAAP metrics. The Company will revise the… response letter →
Childrens Place, Inc. (PLCE) · 2026-01-27 · The Children's Place, Inc. Form 10-K for the Fifty-Two Weeks Ended February 1, 2025 Form 8-K filed April 11, 2025 Form 1 · Comment 3 · Exhibit 99.1, page 1 Agreed to revise
Staff comment: The second line item on page 1 reports the third consecutive quarter of adjusted profit and discussions on pages 3 and 4 discuss adjusted selling, general and administrative expenses and adjusted operating income leveraged basis points and percentages of net sales without presenting or discussing the most directly comparable GAAP measure with equal or greater prominence. Please revise future disclosures to comply with Item 10(e)(1)(i)(A) of Regulation S-K or explain why a revision is not necessary. Refer to Question 102.10(a) of the Staff’s Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. 4. Reference is made to page 7. Please tell us the Adjusted net income (loss)… letter →
Company response: We acknowledge the Staff’s comment and will revise future disclosures to comply with Item 10(e)(1)(i)(A) of Regulation S-K by presenting or discussing the most directly comparable GAAP measure with equal or greater prominence. Exhibit 99.1, page 7 4. Reference is made to page 7. Please tell us the Adjusted net income (loss) effective tax rate for each period presented and explain why it’s reasonable. In this regard, tell us your consideration of including current and deferred income tax expense commensurate with this non-GAAP measure of profitability. Refer to Question 102.11 of the Staff’s Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Response: We acknowledge… response letter →
DULUTH HOLDINGS INC. (DLTH) · 2026-01-27 · Duluth Holdings, Inc. Form 10-K for Fiscal Year Ended February 2, 2025 Annual Report to Security Holders for Fiscal Year · Comment 1 · Financial Results Agreed to revise
Staff comment: Please reconcile Adjusted Diluted EPS, a non-GAAP financial measure presented here and under Summary of Financial Performance, to its most directly comparable GAAP measure. Refer to Item 100(a) of Regulation G. Item 2.02 Form 8-K dated December 16, 2025 Duluth Holdings Inc. Announces Third Quarter 2025 Financial Results Duluth Holdings Inc. letter →
Company response: We respectfully acknowledge the Staff’s comment and we advise that in future annual reports to security holders, we will include a table that reconciles any non-GAAP financial measure to its most directly comparable GAAP measure, including any reconciliations required in our Annual Report to Security Holders for Fiscal Year Ended February 1, 2026. By way of example, the following is a reconciliation of Adjusted Diluted EPS that was included in our earnings release furnished as part of the Current Report on Form 8-K, dated March 11, 2025. DULUTH HOLDINGS INC. Reconciliation of Net Loss to Adjusted Net Loss and Adjusted Net Loss to Adjusted EPS (Unaudited) Three Months Ended Twelve Months… response letter →
DULUTH HOLDINGS INC. (DLTH) · 2026-01-27 · Duluth Holdings, Inc. Form 10-K for Fiscal Year Ended February 2, 2025 Annual Report to Security Holders for Fiscal Year · Comment 2 · (Loss) to Adjusted EPS, page 9 Agreed to revise
Staff comment: We note your non-GAAP adjustment labeled "tax valuation allowance" reflected in your Adjusted Net Income reconciliation. Please tell us what the adjustment represents, the reasons for excluding the changes in your tax valuation from the measure and why management believes the adjustment is meaningful and appropriate. In addition, please tell us how the adjustment is consistent with Questions 100.01 and 102.11 of the Non- GAAP Financial Measures Compliance & Disclosure Interpretations. letter →
Company response: The “tax valuation allowance” adjustment represents a discrete, non-cash charge recorded to establish a valuation allowance against deferred tax assets. We record net deferred tax assets to the extent we believe these assets will more likely than not be realized. A valuation allowance is established if it is more likely than not that some portion or all of the deferred income tax asset will not be realized. The Company considers this a discrete adjustment rather than a reflection of the Company’s ongoing performance. It also does not preclude our business from utilizing the underlying tax credits for which the valuation allowance was established. Management believes excluding this discrete… response letter →
Chewy, Inc. (CHWY) · 2026-01-15 · Form 10-K for Fiscal Year Ended February 2, 2025 Filed March 26, 2025 · Comment 1 · Revenue Recognition, page 60 Agreed to revise
Staff comment: We note you generate revenue from the sale of pet products. We also note your emphasis on pet healthcare, including the provision of pharmacy, veterinary, and telehealth services. As it relates to these expanded service-based offerings, please explain your consideration of Rule 5-03(b) of Regulation S-X requiring separate presentation of revenue and costs of revenue from products, services and other revenues; ASC-606-10-50-5 and 606-10-55-89 through 55-91 requiring disclosure of disaggregated revenue recognized from contracts with customers into categories that depict how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by economic factors; and ASC… letter →
Company response: The Company confirms that management considered Rule 5-03(b) of Regulation S-X and the guidance under ASC-606-10-50-5, ASC 606-10-55-89 through 55-91 and ASC 280-10-50-40 in evaluating the Company’s presentation of revenue and costs of revenue. In evaluating the presentation of revenues and costs of revenues under Rule 5-03(b) of Regulation S-X, management considered whether the Company’s revenues from products, services, and other activities warrant separate presentation on the face of the consolidated statements of operations. Rule 5-03(b) of Regulation S-X provides that “ if income is derived from more than one of the sub-captions described under § 210.5-03.1, each class which is not… response letter →
NEIGHBORHOOD INTELLIGENCE, INC. (NXH, BBBY, BBBYW) · 2026-01-02 · Bed Bath & Beyond, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 · Comment 1 · 25. Business Segments, page 81 Agreed to revise
Staff comment: Your response to prior comment 2 appears to indicate that your CODM utilizes “adjusted” operating income (loss), rather than operating income (loss), to evaluate income generated from segment resources. Please confirm that you will accurately name and describe the measures CODM utilizes to evaluate income generated from segment resources in your future filings. letter →
Company response: to prior comment 2 appears to indicate that your CODM utilizes "adjusted" operating income (loss), rather than operating income (loss), to evaluate income generated from segment resources. Please confirm that you will accurately name and describe the measures CODM utilizes to evaluate income generated from segment resources in your future filings. Company Response : We respectfully acknowledge the Staff’s comment and confirm that the CODM utilizes operating income (loss) to evaluate income generated from segment resources. In future filings, the Company confirms that it will accurately name and describe the measures the CODM utilizes to evaluate income generated from segment resources. * *… response letter →
WILLIAMS SONOMA INC (WSM) · 2025-12-29 · Williams-Sonoma, Inc. Form 10-K for Fiscal Year Ended February 2, 2025 Form 8-K Furnished on March 19, 2025 · Comment 1 · Fiscal 2024 Financial Results, page 35 Awaiting / response not in dataset
Staff comment: Please quantify all factors cited as contributing to variances between periods in your annual and interim period reports. For example (but not all inclusive) in the current annual report, factors cited that are not quantified regarding the change in net revenues in fiscal 2024 from fiscal 2023 include the additional week in fiscal 2024, customer hesitancy towards furniture purchases, offset of strength in non-furniture and seasonal assortments, strategy to reduce promotional activity, collaborations, dorm and baby offerings, seasonal decor, and new product introductions. Refer to section III.D of Release No. 33-6835 (501.04 of the staff’s Codification of Financial Reporting Releases).… letter →
WILLIAMS SONOMA INC (WSM) · 2025-12-29 · Williams-Sonoma, Inc. Form 10-K for Fiscal Year Ended February 2, 2025 Form 8-K Furnished on March 19, 2025 · Comment 2 · relative magnitude. Awaiting / response not in dataset
Staff comment: On page 35 you disclose decreased revenue in fiscal 2024 for Pottery Barn was due in part to your strategy to reduce promotional activity, whereas on page 40 you disclose increased SG&A in fiscal 2024 was in part due to an increase in advertising expenses. Please reconcile these disclosures for us and revise your disclosures as appropriate. letter →
WILLIAMS SONOMA INC (WSM) · 2025-12-29 · Williams-Sonoma, Inc. Form 10-K for Fiscal Year Ended February 2, 2025 Form 8-K Furnished on March 19, 2025 · Comment 3 · Cash Flows from Operating Activities, page 42 Awaiting / response not in dataset
Staff comment: It appears the increase of $82.8 million in cash paid for income taxes, net of refunds, in fiscal 2024 compared to fiscal 2023 is a material item that is not disclosed as a factor in your analysis of changes in operating cash flows. Please discuss all material usages of cash as appropriate. Refer to Item 303(a) and (b) of Regulation S-K. Additionally, quantify each variance factor cited in annual and interim period reports. letter →
WILLIAMS SONOMA INC (WSM) · 2025-12-29 · Williams-Sonoma, Inc. Form 10-K for Fiscal Year Ended February 2, 2025 Form 8-K Furnished on March 19, 2025 · Comment 4 · Return on Invested Capital, page 11 Awaiting / response not in dataset
Staff comment: You make adjustments to both the numerator and denominator in your calculation of Return on Invested Capital. As it appears your calculation is not that as typically calculated, it appears you should qualify the label of the measure as "adjusted" or some other appropriate description. Also, please explain the purpose and basis for all adjustments made and disclose what the measure is intended to represent and why your measure provides useful information to investors. Lastly, present this measure calculated using the most directly comparable GAAP measures. Refer to Item 10(e)(1)(i) of Regulation S-K and the third bullet under Question 102.10(a) and by analogy to Questions 102.02 and 103.01… letter →
Krispy Kreme, Inc. (DNUT) · 2025-12-11 · Form 10-K for Fiscal Year Ended December 29, 2024 · Comment 1 · Non-GAAP Measures, page 40 Awaiting / response not in dataset
Staff comment: Please expand your footnote (2) on page 42 to quantify the components included in the adjustment for strategic initiatives for all periods presented. letter →
Krispy Kreme, Inc. (DNUT) · 2025-12-11 · Form 10-K for Fiscal Year Ended December 29, 2024 · Comment 2 · the adjustment for strategic initiatives for all periods presented. Awaiting / response not in dataset
Staff comment: Please quantify the components included in your tax specific adjustments and tell us your purpose for including these adjustments in your non-GAAP measure presentation. Please explain why these adjustments do not substitute individually tailored recognition and measurement methods for those of GAAP. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Results of Operations by Segment - Fiscal Year ended December 29, 2024 compared to the Fiscal Year ended December 31, 2023, page 48 3. Segment Adjusted EBIT (rather than segment Adjusted EBITDA) appears to be your primary measure of segment profitability under ASC 280. Please discuss with… letter →
RIKU DINING GROUP Ltd · 2025-12-04 · Amendment No. 2 to Registration Statement on Form F-1 Filed November 18, 2025 Amendment No. 1 to Registration Statement · Comment 2 · 1. We note your response to prior comment Awaiting / response not in dataset
Staff comment: Please further revise to provide the information called for by Item 6.B of Form 20-F "for the last full financial year." Consolidated Financial Statements, page F-1 2. Please provide updated audited financial statements, or file as an exhibit to the filing the representations as to why such update is not necessary. Refer to Item 8.A.4 of Form 20-F and Instruction 2 to Item 8.A.4. letter →
RIKU DINING GROUP Ltd · 2025-12-04 · Amendment No. 2 to Registration Statement on Form F-1 Filed November 18, 2025 Amendment No. 1 to Registration Statement · Comment 3 · Item 7. Recent Sales of Unregistered Securities, page II-1 Awaiting / response not in dataset
Staff comment: Given your disclosure that "the Company completed a reclassification of its ordinary shares," and "issued new shares to its existing shareholders without any change to the percentage of shares held by each existing shareholder," please revise to provide the information called for by Item 701 of Regulation S-K, or advise. letter →
NEIGHBORHOOD INTELLIGENCE, INC. (NXH, BBBY, BBBYW) · 2025-11-18 · Bed Bath & Beyond, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Item 2.02 Form 8-K Dated October 27, 2025 Resp · Comment 1 · Note 22. Other Expense, Net, page 77 Awaiting / response not in dataset
Staff comment: Refer to prior comment 3. You indicate in your response that the errors in multiple reporting periods were related to four discrete items. As the quantitative magnitude of the errors increase, it is increasingly difficult for qualitative factors to overcome the quantitative significance of the errors. Please tell us in further detail how you determined the qualitative factors overcame the quantitative significance of the errors to your Operating Income (Loss) in each of the following periods: • fiscal year ended December 31, 2023, • the three and six months ended June 30, 2025 and • the three and six months ended June 30, 2024. Also, it appears in your quantitative analysis that you have… letter →
NEIGHBORHOOD INTELLIGENCE, INC. (NXH, BBBY, BBBYW) · 2025-11-18 · Bed Bath & Beyond, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Item 2.02 Form 8-K Dated October 27, 2025 Resp · Comment 3 · 2. Refer to prior comment Awaiting / response not in dataset
Staff comment: You disclose in your segment footnote that your "CODM uses Operating Income (Loss) to evaluate income generated from segment resources in deciding whether to reinvest profits into the retail segment or into other parts of the entity, such as to make acquisitions or investments. The CODM also uses Operating Income (Loss) to monitor budget versus actual results. The monitoring of budgeted versus actual results is used in assessing performance of the segment and in establishing bonus metrics." Please discuss in detail how this process works and incorporate your consideration of the importance of Operating Income (Loss) to your CODM into your materiality assessment. Item 9A. Controls and… letter →
NEIGHBORHOOD INTELLIGENCE, INC. (NXH, BBBY, BBBYW) · 2025-11-18 · Bed Bath & Beyond, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Item 2.02 Form 8-K Dated October 27, 2025 Resp · Comment 4 · Non-GAAP Financial Measures and Reconciliations, page 7 Awaiting / response not in dataset
Staff comment: Please address the following as they relate to adjusted diluted net loss per share in prior comment 4: • Confirm that you will disclose prior year comparative information; • Confirm that you will disclose, at a similar level as you provided in your response letter dated September 18, 2025, the reasons why management believes that adjusting for income/loss relating to equity method securities and the gain/loss on debt securities carried at fair value in arriving at adjusted diluted net loss per share provides useful information to investors; and • Confirm that you will present the income tax effect separately from other non- GAAP adjustments as it does not appear that you have done so in… letter →
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