BED BATH & BEYOND, INC. (NXH, BBBY, BBBYW) – Company response

Total Mix of Information As noted above, SAB 99 defines materiality by reference to whether there is a substantial likelihood that the misstatement would have changed or influenced the judgment of a reasonable investor based on the “total mix” of information. SAB 99 emphasizes that assessment of materiality requires consideration of both quantitative and qualitative factors, that magnitude alone is generally insufficient, and that exclusive reliance on “ any percentage or numerical threshold has no basis in the accounting literature or the law” (emphasis added). Applying SAB 99 and SAB 108 to…