Earnings per Share (ASC 260)

Company response: * * * * * response letter →

Company response: The Company acknowledges the Staff’s comment and confirms that the Company has considered the guidance in Question 100.01 of the Corporation Finance Interpretations on Non-GAAP Financial Measures. The Company confirms that the adjustment for these costs are not part of normal operations, as discussed below, and that the Company believes that the Company’s presentation of diluted earnings per share from continuing operations before charges/gains and operating income and margin before charges/gains shown is appropriate under the circumstances to give investors a representation of normal operating performance and period-to-period comparability. The items included as adjustments within “other… response 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 →

Company response: The Company advises the Staff on a supplemental basis that the Company's earnings per share (“ EPS ”) amounts have been computed based on the weighted-average number of shares of common stock outstanding for the period under the two-class method in a ccordance with Accounting Standards Codification (“ ASC ”) 260-10-45-60A. Basic EPS is computed by dividing net increase (decrease) in net assets resulting from operations applicable to common shareholders (adjusted for income allocated to participating securities, which relates to the unvested shares of restricted stock awarded pursuant to the Company’s equity compensation plans) by the weighted average number of shares of common stock… response 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 →

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 →

Company response: Albany International Corp. (the “Company” or “we”) respectfully submits the following response to the comment included in your letter of December 15, 2025 referenced above. For your convenience, your comment is repeated below in italics followed by the Company’s response. We note you present several non-GAAP financial measures including Adjusted net revenues, Adjusted gross profit/(loss), Adjusted gross profit/(loss) margin, Adjusted EBITDA, Adjusted EBITDA margin, Adjusted net income, and Adjusted earnings per share attributable to the Company shareholders – diluted. We also note that these measures exclude the CH-53K loss contract reserve and program adjustments. Although disclosing the… response letter →