Correspondence 0001437749-23-003239 from LSI INDUSTRIES INC (LYTS)
LSI INDUSTRIES INC
Date: Feb. 14, 2023 · CIK: 0000763532 · Accession: 0001437749-23-003239
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File numbers found in text: 000-13375
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CORRESP 1 filename1.htm lyts20230213_corresp.htm February 14, 2023 Via Edgar Hugh West Branch Chief U.S. Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549 Re: LSI Industries Inc. Form 10-K for the fiscal year ended June 30, 2022 Filed September 9, 2022 File No. 000-13375 Dear Hugh West: This letter responds to your letter, dated February 7, 2023, regarding our Form 10-K for the fiscal year ended June 30, 2022. Your comment is set forth below, followed by our response. 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. Response: We acknowledge your comment and direction, and we will revise our presentation in future annual and quarterly reports and, as applicable, our Form 8-K reports to reconcile EBITDA and Adjusted EBITDA to net income. You may contact me at (513) 793-3200 with any questions. Sincerely, LSI INDUSTRIES INC. By: /s/ James E. Galeese James E. Galeese Chief Financial Officer cc: F. Mark Reuter, Keating Muething & Klekamp PLL