SEC Comment Letter 0000000000-23-005004 to LEVI STRAUSS & CO (LEVI) (CIK 0000094845) (LEVI)
LEVI STRAUSS & CO (LEVI) (CIK 0000094845)
Date: May 11, 2023 · CIK: 0000094845 · Accession: 0000000000-23-005004
AI Filing Summary & Sentiment
File numbers found in text: 001-06631
Referenced dates: May 2, 2023
Letter
United States securities and exchange commission logo May 11, 2023 Nanci Prado Deputy General Counsel LEVI STRAUSS & CO. 1155 Battery Street San Francisco, CA 94111 Re:LEVI STRAUSS & CO. Form 10-K for the Fiscal Year Ended November 27, 2022 Response Dated May 2, 2023 File No. 001-06631 Dear Nanci Prado: We have reviewed your May 2, 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 April 18, 2023 letter. Response Letter Dated May 2, 2023 Appendix A, page 5 1.We note that on the last page of Appendix A, you disclose Adjusted Diluted Earnings Per Share at the bottom of your reconciliation of net income to Adjusted Net Income. Please revise to present a reconciliation of diluted EPS to Adjusted Diluted EPS. Additionally, wherever you present a Non GAAP margin measure in Appendix A, please revise to disclose the most comparable margin presented in accordance with GAAP.
FirstName LastNameNanci Prado Comapany NameLEVI STRAUSS & CO. May 11, 2023 Page 2 FirstName LastName Nanci Prado LEVI STRAUSS & CO. May 11, 2023 Page 2 You may contact Stephany Yang at (202) 551-3167 or Claire Erlanger at (202) 551- 3301 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
May 11, 2023
Nanci Prado
Deputy General Counsel
LEVI STRAUSS & CO.
1155 Battery Street
San Francisco, CA 94111
Re:LEVI STRAUSS & CO.
Form 10-K for the Fiscal Year Ended November 27, 2022
Response Dated May 2, 2023
File No. 001-06631
Dear Nanci Prado:
We have reviewed your May 2, 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
April 18, 2023 letter.
Response Letter Dated May 2, 2023
Appendix A, page 5
1.We note that on the last page of Appendix A, you disclose Adjusted Diluted Earnings Per
Share at the bottom of your reconciliation of net income to Adjusted Net Income. Please
revise to present a reconciliation of diluted EPS to Adjusted Diluted EPS. Additionally,
wherever you present a Non GAAP margin measure in Appendix A, please revise to
disclose the most comparable margin presented in accordance with GAAP.
FirstName LastNameNanci Prado
Comapany NameLEVI STRAUSS & CO.
May 11, 2023 Page 2
FirstName LastName
Nanci Prado
LEVI STRAUSS & CO.
May 11, 2023
Page 2
You may contact Stephany Yang at (202) 551-3167 or Claire Erlanger at (202) 551-
3301 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing