SecProbe.io

September 18, 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, 2024
Form 10-K for the Fiscal Year Ended April 30, 2023
Response dated July 24, 2024
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 for the Fiscal Year Ended April 30, 2024
Note 18 - Business Segments, page 67
1.We note your response to prior comment 3. Please tell us:
•whether the CODM approves the product/title budgets;
•the level at which the CODM makes changes to the product/title budgets during his
review. For example, tell us whether the CODM requests changes to amounts within
individual product/title budgets;
•whether the product/title budgets are consistent with the example monthly operating
statement provided in your prior response. If different, please describe the
differences; and
•whether the board of directors receives product/title budgets, whether they receive
product/title budget versus actual information during the year, and if so, with what
frequency.

September 18, 2024
Page 2
2.We note your response to prior comment 4. Please tell us what product/title-oriented
financial information the CODM considers when making the following types of decisions
cited in your response to comment 2 in your May 10, 2024 letter:
•increasing or decreasing different categories of advertising expense;
•asking that certain ideas receive more attention;
•introducing or discontinuing a product/title;
•deciding product pricing; and
•deciding compensation.

As part of your response, specifically address whether the CODM would consider the
salaries and accrued salaries, benefits, allocations, or total income (loss) information line
items for products/titles as contained in the example monthly operating statement
included in your prior response when making the above decisions.
3.As it relates to the decisions referenced above and in your response to comment 2 in your
May 10, 2024 letter, please also tell us in further detail, with supporting examples, what
the CODM “[asking] that certain ideas receive more attention” represents. Specifically,
tell us whether more attention, in this context, means additional resources and whether
that occurs at the product/title level. In regard to the reference to the CODM deciding
compensation, tell us what types of compensation are considered and decided, describe
which employees and their roles that it relates to, and whether the compensation relates to
specific products/titles.
4.You indicate in your response to prior comment 4 that except for certain direct variable
costs to produce and distribute a product, other expenses are allocated to the product/titles
in an arbitrary or discretionary manner as proposed to the CODM by the PAO. Please
address the following:
•Clarify precisely which types and line items of expenses, as presented in the example
monthly operating statement included in your prior response, are direct and which are
allocated.
•For expenses that are allocated, describe the methodology used to allocate them. If
amounts are allocated in a discretionary manner, describe the basis for the allocation.
If a formula is used, describe the methodology.
•If the direct expenses and allocations used in the example monthly operating
statement are not representative of all products/titles, please provide additional
information to assist our understanding.
•Tell us whether amounts included in the “Salaries & Accrued Salaries” item
presented in the example monthly operating statement are specific to that given
product/title.
•Describe and quantify the nature of the costs included in the “Allocations” item.
We note your response to prior comment 6. However, you also indicate in your response
to comment 2 in your May 10, 2024 letter that “[m]anagement feels that as long as the
cost allocation methods are consistent, they assist the CODM and PAO from year to year
in evaluating major changes or variations; indeed the PAO prepares variance reports to
highlight such differences.” Further, it appears “Total Income (Loss)” is available for each 5.

September 18, 2024
Page 3
product/title based on its inclusion in the example monthly operating statement included
in your prior response. Please address the following:
•Tell us what decisions the CODM makes based on his review of the variance reports,
including any changes the CODM makes changes in the allocation of resources to
products/titles.
•Explain in further detail why you believe discrete financial information does not exist
at the product/title level. Refer to ASC 280-10-50-1(c).
            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