SEC Comment Letter 0000000000-23-001271 to LSI INDUSTRIES INC (LYTS)
LSI INDUSTRIES INC
Date: Feb. 7, 2023 · CIK: 0000763532 · Accession: 0000000000-23-001271
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File numbers found in text: 000-13375
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United States securities and exchange commission logo
February 7, 2023
James Galeese
Chief Financial Officer
LSI INDUSTRIES INC
10000 Alliance Road
Cincinnati, OH 45242
Re:LSI INDUSTRIES INC
Form 10-K for the fiscal year ended June 30, 2022
Filed September 9, 2022
File No. 000-13375
Dear James Galeese:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the fiscal year ended June 30, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 26
1.We note that you reconcile EBITDA and Adjusted EBITDA to operating income. Please
revise your presentation in future annual and quarterly filings to reconcile these non-
GAAP measures to net income, the most directly comparable GAAP measure. Refer to
Item 10(e)(1)(i)(B) of Regulations S-K and Question 103.02 of the SEC’s Division of
Corporation Finance C&DIs on Non-GAAP Measures. This comment also applies to your
earnings releases furnished on Form 8-K.
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.
FirstName LastNameJames Galeese
Comapany NameLSI INDUSTRIES INC
February 7, 2023 Page 2
FirstName LastName
James Galeese
LSI INDUSTRIES INC
February 7, 2023
Page 2
You may contact Mindy Hooker, Accountant, at (202) 551-3732 or Hugh West, Branch
Chief, at (202) 551-3872 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing