Correspondence 0001558370-24-012488 from TOOTSIE ROLL INDUSTRIES INC (TR, TROLB) (CIK 0000098677) (TR)
TOOTSIE ROLL INDUSTRIES INC (TR, TROLB) (CIK 0000098677)
Date: Aug. 27, 2024 · CIK: 0000098677 · Accession: 0001558370-24-012488
AI Filing Summary & Sentiment
File numbers found in text: 001-01361
Referenced dates: August 9, 2024
Letter
VIA EDGAR Division of Corporate Finance Securities and Exchange Commission Filed March 25, 2024 File No. 001-01361
Dear Ms. Ravitz:
We respectfully submit the following responses to your comments in the subject letter. Should you have any questions or need additional information, please do not hesitate to contact me at bbowen@tootsie-roll.com or (773) 838-3431.
Definitive Proxy Statement on Schedule 14A
Pay v Performance, page 18
1. Instead of net earnings, you use a figure that deducts earnings attributable to non-controlling interests. Please confirm that, in future filings, you will use net earnings (loss) without such a deduction.
Response: Confirmed – the reported amount in the table will be net earnings. A reconciliation of this figure to how Tootsie Roll otherwise reports net earnings for other purposes may be provided as a supplement to this disclosure.
2. Please confirm that, in future filings, you will amend the header in the pay versus performance chart to indicate that you have only one Company-Selected Measure.
Response: Confirmed. The term “Company Selected Measure” will only be over one column to the Summary Compensation Table.
3. Please confirm that, in future filings, you will provide a comparison of your cumulative total shareholder return and the cumulative total shareholder return of your peer group over the same period.
Response: Confirmed.
The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, actions or absence of actions by Commission staff.
Sincerely,
TOOTSIE ROLL INDUSTRIES, INC.
Show Raw Text
CORRESP 1 filename1.htm Tootsie Roll Industries, Inc 7401 SOUTH CICERO AVENUE • CHICAGO, ILLINOIS 60629 • (773) 838-3400 FAX (773) 838-3534 August 27, 2024 VIA EDGAR Ms. Amanda Ravitz Division of Corporate Finance Securities and Exchange Commission 100F Street, NE Washington, D.C. 20549 Re: Comment Letter Dated August 9, 2024 Tootsie Roll Industries, Inc. Definitive Proxy Statement on Schedule 14A Filed March 25, 2024 File No. 001-01361 Dear Ms. Ravitz: We respectfully submit the following responses to your comments in the subject letter. Should you have any questions or need additional information, please do not hesitate to contact me at bbowen@tootsie-roll.com or (773) 838-3431. Definitive Proxy Statement on Schedule 14A Pay v Performance, page 18 1. Instead of net earnings, you use a figure that deducts earnings attributable to non-controlling interests. Please confirm that, in future filings, you will use net earnings (loss) without such a deduction. Response: Confirmed – the reported amount in the table will be net earnings. A reconciliation of this figure to how Tootsie Roll otherwise reports net earnings for other purposes may be provided as a supplement to this disclosure. 2. Please confirm that, in future filings, you will amend the header in the pay versus performance chart to indicate that you have only one Company-Selected Measure. Response: Confirmed. The term “Company Selected Measure” will only be over one column to the Summary Compensation Table. 3. Please confirm that, in future filings, you will provide a comparison of your cumulative total shareholder return and the cumulative total shareholder return of your peer group over the same period. Response: Confirmed. The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, actions or absence of actions by Commission staff. Sincerely, TOOTSIE ROLL INDUSTRIES, INC. /s/ Barry Bowen Barry Bowen Treasurer