SEC Comment Letter 0000000000-23-006606 to TrueBlue, Inc. (TBI) (CIK 0000768899) (TBI)
TrueBlue, Inc. (TBI) (CIK 0000768899)
Date: June 21, 2023 · CIK: 0000768899 · Accession: 0000000000-23-006606
AI Filing Summary & Sentiment
File numbers found in text: 001-14543
Letter
United States securities and exchange commission logo June 21, 2023 Steven Cooper President and Chief Executive Officer TrueBlue, Inc. P.O. Box 2910 1015 A Street Tacoma, WA 98402 Re:TrueBlue, Inc. Form 10-K for the Fiscal Year Ended December 25, 2022 Filed February 15, 2023 Form 8-K Filed April 24, 2023 File No. 001-14543 Dear Steven Cooper: We have reviewed your filings and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 8-K Filed April 24, 2023 Exhibit 99.3 Investor Roadshow Presentation, page 4 1.We note your presentation of the non-GAAP measures, average return on equity and return on equity, on pages 4 and 15 of this exhibit. Please revise your disclosure to also disclose the most directly comparable GAAP measure. Please refer to the guidance in Regulation G. 2.We note your disclosure of the non-GAAP measure, EBITDA margin, on page 5 of this exhibit. Please revise to also disclose the most directly comparable GAAP measure and provide a reconciliation of this non-GAAP measure to the most comparable GAAP measure. Refer to the guidance in Regulation G.
FirstName LastNameSteven Cooper Comapany NameTrueBlue, Inc. June 21, 2023 Page 2 FirstName LastName Steven Cooper TrueBlue, Inc. June 21, 2023 Page 2 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. You may contact Angela Lumley at 202-551-3398 or Linda Cvrkel at 202-551-3813 if you have questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
June 21, 2023
Steven Cooper
President and Chief Executive Officer
TrueBlue, Inc.
P.O. Box 2910
1015 A Street
Tacoma, WA 98402
Re:TrueBlue, Inc.
Form 10-K for the Fiscal Year Ended December 25, 2022
Filed February 15, 2023
Form 8-K Filed April 24, 2023
File No. 001-14543
Dear Steven Cooper:
We have reviewed your filings and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 8-K Filed April 24, 2023
Exhibit 99.3
Investor Roadshow Presentation, page 4
1.We note your presentation of the non-GAAP measures, average return on equity and
return on equity, on pages 4 and 15 of this exhibit. Please revise your disclosure to also
disclose the most directly comparable GAAP measure. Please refer to the guidance in
Regulation G.
2.We note your disclosure of the non-GAAP measure, EBITDA margin, on page 5 of this
exhibit. Please revise to also disclose the most directly comparable GAAP measure and
provide a reconciliation of this non-GAAP measure to the most comparable GAAP
measure. Refer to the guidance in Regulation G.
FirstName LastNameSteven Cooper
Comapany NameTrueBlue, Inc.
June 21, 2023 Page 2
FirstName LastName
Steven Cooper
TrueBlue, Inc.
June 21, 2023
Page 2
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.
You may contact Angela Lumley at 202-551-3398 or Linda Cvrkel at 202-551-3813 if
you have questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services