SecProbe.io

United States securities and exchange commission logo
March 1, 2024
Steve Anastasio
Vice President, Treasurer and Director
Value Line Inc.
551 Fifth Avenue
New York, NY 10176
Re:Value Line Inc.
Form 10-K for the Fiscal Year Ended April 30, 2023
Filed July 28, 2023
File No. 000-11306
Dear Steve Anastasio:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K filed July 28, 2023
Exhibit 99.1, page 46
1.We note that you filed separate financial statements of EULAV Asset Management as of
April 30, 2023 pursuant to Rule 3-09 of Regulation S-X. In regard to the single year
financial statement period presented, please tell us how you have considered and
complied with Rule 3-09(b) of Regulation S-X.
Note 18 - Business Segments, page 72
2.We note your disclosure that the Company has a single reportable segment. We also note
disclosure throughout your filing referring to various revenue streams (e.g., institutional
and investment periodicals and related publications vs. copyright fees), specific
publications product lines, type of customer (e.g., retail vs. institutional) and subscription
type (e.g., print vs. digital). In light of these various revenue streams and sales categories,
please provide us with an ASC 280 segment identification analysis, including information
on the following:

 FirstName LastNameSteve  Anastasio
 Comapany NameValue Line Inc.
 March 1, 2024 Page 2
 FirstName LastNameSteve  Anastasio
Value Line Inc.
March 1, 2024
Page 2
•Provide us with details on your current management structure and how
your Company is organized, including an organizational chart.
•Describe the role of your Chief Operating Decision Maker ("CODM") and each of
the individuals reporting to the CODM.
•Identify and describe the role of each of your product area or other sales category
managers and leadership team, and your analysis of whether any of your managers
represent segment managers based on ASC 280-10-50-7.
•Describe the key operating decisions, who makes these decisions, how performance
is assessed and how resources are allocated within your business.
•Tell us how often the CODM meets with his direct reports and product area
managers, the financial information the CODM reviews in conjunction with those
meetings and the other participants at those meetings.
•Explain how budgets are prepared, who approves the budget at each step of the
process, the level of detail discussed at each step, and the level at which the CODM
makes changes to the budget.
•Describe the basis for determining the compensation for each individual that reports
to the CODM.
3.As part of your segment identification analysis, describe the financial information
reviewed by the CODM for the purpose of allocating resources and assessing
performance. In this regard, we note your disclosure, on page 26, indicating that some
publications having higher-profits compared to those of lower price “starter” products. We
also note your references to retail and institutional sales departments, and some related
discussion of retail and institutional sales commissions. Please tell us whether the CODM
receives disaggregated financial information and margin information at a lower level than
consolidated, such as by product or product area or for your retail and institutional sales,
and, if so, describe it in detail, how frequently it is provided, and how it is used by the
CODM. In addition, describe the key business objectives that are tracked and discussed
with the product area or other leaders. Finally, describe the financial information provided
to the Board of Directors and how frequently that information is reviewed.
4.We note your disclosure that your investment in EAM is not considered to be a reportable
business segment due to your lack of control over the operating and financial policies of
EAM. Please tell us how you considered the guidance in ASC 280-10-55-2 in your
determination that the investment in EAM is not a reportable segment.
5.We note your disclosure on pages 13 and 21 indicating that investment periodicals and
related publications (retail and institutional) and Value Line copyrights and Value Line
Proprietary Ranks and other proprietary information are consolidated into one segment
called Publishing. Please address the following:
•Clarify whether the Company has more than one operating segments based on ASC
280-10-50-1 and provide an accompanying accounting analysis.
•Explain the meaning of "consolidated into one segment" in this context and whether
it is intended to refer to aggregation in accordance with ASC 280-10-50-11. If so,

 FirstName LastNameSteve  Anastasio
 Comapany NameValue Line Inc.
 March 1, 2024 Page 3
 FirstName LastName
Steve  Anastasio
Value Line Inc.
March 1, 2024
Page 3
please provide us with your aggregation analysis, including specific details of the
quantitative and qualitative factors considered.
6.Please revise your segment footnote disclosures to provide all information required by
ASC 280. For example, your disclosure should include, but not be limited to, the basis of
organization information used to identify the Company's reportable segments in
accordance with ASC 280-10-50-21 and entity-wide information required by ASC 280-
10-50-38 through 42.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Lory Empie at 202-551-3714 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance