SEC Comment Letter 0000000000-24-010533 to DENNY'S Corp (DENN) (CIK 0000852772)
DENNY'S Corp (DENN) (CIK 0000852772)
Date: Sept. 17, 2024 · CIK: 0000852772 · Accession: 0000000000-24-010533
AI Filing Summary & Sentiment
File numbers found in text: 000-18051
Letter
September 17, 2024 Robert Verostek Executive Vice President and Chief Financial Officer Denny's Corporation 203 East Main Street Spartanburg SC, 29319-0001 Re:Denny's Corporation Form 10-K for the Fiscal Year Ended December 27, 2023 Form 8-K filed July 30, 2024 File No. 000-18051 Dear Robert Verostek: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). 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 8-K filed July 30, 2024 Exhibit 99.1- Press Release, dated July 30, 2024 Reconciliation of Net Income to Non-GAAP Financial Measures, page 8 1.We note your adjustments for legal settlement expenses, pre-opening expenses and other adjustments in your reconciliation of Adjusted EBITDA and Adjusted Net Income. Please tell us how you determined that these costs are not normal, recurring, cash operating expenses necessary to operate your business. Refer to Question 100.01 of the Non- GAAP Financial Measures Compliance and Disclosure Interpretations.
September 17, 2024 Page 2 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 Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Jay Gilmore
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September 17, 2024
Robert Verostek
Executive Vice President and Chief Financial Officer
Denny's Corporation
203 East Main Street
Spartanburg SC, 29319-0001
Re:Denny's Corporation
Form 10-K for the Fiscal Year Ended December 27, 2023
Form 8-K filed July 30, 2024
File No. 000-18051
Dear Robert Verostek:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
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 8-K filed July 30, 2024
Exhibit 99.1- Press Release, dated July 30, 2024
Reconciliation of Net Income to Non-GAAP Financial Measures, page 8
1.We note your adjustments for legal settlement expenses, pre-opening expenses and other
adjustments in your reconciliation of Adjusted EBITDA and Adjusted Net Income. Please
tell us how you determined that these costs are not normal, recurring, cash operating
expenses necessary to operate your business. Refer to Question 100.01 of the Non-
GAAP Financial Measures Compliance and Disclosure Interpretations.
September 17, 2024
Page 2
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 Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jay Gilmore