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SEC Company Response from MARCUS CORP (MCS) (CIK 0000062234) (MCS) — Jul 11, 2008

MARCUS CORP (MCS) (CIK 0000062234)
Date: July 11, 2008 · CIK: 0000062234 · Accession: 0000897069-08-001148

Financial Reporting Regulatory Compliance Business Model Clarity

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: June 4, 2008

Date
July 11, 2008
Author
/s/ Steven R. Barth
Form
CORRESP
Company
MARCUS CORP (MCS) (CIK 0000062234)

Letter

VIA EDGAR AND FEDERAL EXPRESS Mr. Kevin Woody Accounting Branch Chief Division of Corporation Finance U.S. Securities and Exchange Commission F Street, N.E. Washington, DC 20549-3561 Re: The Marcus Corporation Form 10-K for Fiscal Year Ended May 31, 2007 Filed August 14, 2007

Dear Mr. Woody:

After further discussions with Karen Garnett and Kristina Aberg of the Staff of the Securities and Exchange Commission (the “Staff”), in further response to Comment Number 2 of the Staff’s letter, dated June 4, 2008, with respect to the above-referenced filing, our client, The Marcus Corporation, a Wisconsin corporation (the “Company”), will comply with the Staff’s comment and disclose in its future relevant filings the actual aggregated and averaged amounts of RevPAR, occupancy percentage and average daily room rates for its comparable owned hotels and resorts for the periods reported.

If the Staff has any questions with respect to the foregoing, please contact the undersigned at (414) 297-5662 or Thomas F. Kissinger, the Company’s Vice President, General Counsel and Secretary, at (414) 905-1390.

Very truly yours,
/s/ Steven R. Barth

Show Raw Text
CORRESP
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filename1.htm

     ATTORNEYS AT LAW

     777 EAST WISCONSIN AVENUE

MILWAUKEE, WISCONSIN  53202-5306

414.271.2400 TEL

414.297.4900  FAX

www.foley.com

     July 11, 2008

     WRITER'S DIRECT LINE

414.297.5662
sbarth@foley.com Email

CLIENT/MATTER NUMBER

052560-0725

VIA EDGAR AND FEDERAL EXPRESS

Mr. Kevin Woody
Accounting Branch Chief

Division of Corporation Finance
U.S. Securities and Exchange Commission
100
F Street, N.E.
Washington,
DC 20549-3561

Re:
The
Marcus Corporation
Form 10-K for Fiscal
Year Ended May 31, 2007
Filed August 14, 2007

Dear Mr. Woody:

        After
further discussions with Karen Garnett and Kristina Aberg of the Staff of the Securities
and Exchange Commission (the “Staff”), in further response to Comment Number 2 of
the Staff’s letter, dated June 4, 2008, with respect to the above-referenced
filing, our client, The Marcus Corporation, a Wisconsin corporation (the
“Company”), will comply with the Staff’s comment and disclose in its future
relevant filings the actual aggregated and averaged amounts of RevPAR, occupancy
percentage and average daily room rates for its comparable owned hotels and resorts for
the periods reported.

        If
the Staff has any questions with respect to the foregoing, please contact the undersigned
at (414) 297-5662 or Thomas F. Kissinger, the Company’s Vice President, General
Counsel and Secretary, at (414) 905-1390.

     Very truly yours,

     /s/ Steven R. Barth

     Steven R. Barth

cc:
Douglas
Neis – The Marcus Corporation
Thomas Kissinger – The Marcus Corporation

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