SEC Comment Letter 0000000000-23-007471 to HASBRO, INC. (HAS)
HASBRO, INC.
Date: July 12, 2023 · CIK: 0000046080 · Accession: 0000000000-23-007471
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-06682
Referenced dates: June 28, 2023
Letter
United States securities and exchange commission logo July 12, 2023 Gina Goetter Chief Financial Officer HASBRO, INC. 1027 Newport Avenue Pawtucket, Rhode Island 02861 Re:HASBRO, INC. Form 10-K for the Fiscal Year Ended December 25, 2022 Form 8-K Furnished February 16, 2023 Response Dated June 28, 2023 File No. 001-06682 Dear Gina Goetter: We have reviewed your June 28, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our May 30, 2023 letter. Response Letter Dated June 28, 2023 Company Response to Staff Comment 1 1.We note your response to comment 1 and that your adjustment for the Operational Excellence program includes transformation office and third-party consultant fees that are temporary costs to support transformational efforts. Please further quantify and describe the specific costs for this portion as these efforts appear to be a normal part of managing your growth and business and part of your multi-year Blueprint 2.0 strategy. Company Response to Staff Comment 6 2.We note your response to comment 6. Please revise to clearly explain the nature of the significant amounts included in the "Corporate and Other" line item of operating profit
FirstName LastNameGina Goetter Comapany NameHASBRO, INC. July 12, 2023 Page 2 FirstName LastName Gina Goetter HASBRO, INC. July 12, 2023 Page 2 (loss). In addition, ASC 280-10-50-30b) requires a reconciliation of the total of the reportable segments’ measures of profit or loss to the public entity's consolidated income before income taxes. We note Corporate and Other does not appear to qualify as a reportable segment, and operating profit (loss) is not reconciled to the consolidated earnings before income taxes. Please revise your reconciliation to comply with this guidance. You may contact Stephany Yang at (202) 551-3167 or Melissa Gilmore at (202) 551- 3777 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
July 12, 2023
Gina Goetter
Chief Financial Officer
HASBRO, INC.
1027 Newport Avenue
Pawtucket, Rhode Island 02861
Re:HASBRO, INC.
Form 10-K for the Fiscal Year Ended December 25, 2022
Form 8-K Furnished February 16, 2023
Response Dated June 28, 2023
File No. 001-06682
Dear Gina Goetter:
We have reviewed your June 28, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
May 30, 2023 letter.
Response Letter Dated June 28, 2023
Company Response to Staff Comment 1
1.We note your response to comment 1 and that your adjustment for the Operational
Excellence program includes transformation office and third-party consultant fees that are
temporary costs to support transformational efforts. Please further quantify and describe
the specific costs for this portion as these efforts appear to be a normal part of managing
your growth and business and part of your multi-year Blueprint 2.0 strategy.
Company Response to Staff Comment 6
2.We note your response to comment 6. Please revise to clearly explain the nature of the
significant amounts included in the "Corporate and Other" line item of operating profit
FirstName LastNameGina Goetter
Comapany NameHASBRO, INC.
July 12, 2023 Page 2
FirstName LastName
Gina Goetter
HASBRO, INC.
July 12, 2023
Page 2
(loss). In addition, ASC 280-10-50-30b) requires a reconciliation of the total of the
reportable segments’ measures of profit or loss to the public entity's consolidated income
before income taxes. We note Corporate and Other does not appear to qualify as a
reportable segment, and operating profit (loss) is not reconciled to the consolidated
earnings before income taxes. Please revise your reconciliation to comply with this
guidance.
You may contact Stephany Yang at (202) 551-3167 or Melissa Gilmore at (202) 551-
3777 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing