SEC Comment Letter 0000000000-24-011811 to DENNY'S Corp (DENN) (CIK 0000852772)
DENNY'S Corp (DENN) (CIK 0000852772)
Date: Oct. 22, 2024 · CIK: 0000852772 · Accession: 0000000000-24-011811
AI Filing Summary & Sentiment
File numbers found in text: 000-18051
Letter
October 22, 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 Response dated October 9, 2024 File No. 000-18051 Dear Robert Verostek: We have reviewed your October 9, 2024 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our September 17, 2024 letter. 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 response to prior comment 1. Please further explain the nature of your legal settlement expenses including your basis for concluding each component of this adjustment is consistent with the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Given your growth strategy to increase your restaurants, it appears that pre-opening expenses are normal, recurring, cash operating expenses necessary to operate your core business. Please revise or advise.
October 22, 2024 Page 2 Please contact Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Jay Gilmore
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October 22, 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
Response dated October 9, 2024
File No. 000-18051
Dear Robert Verostek:
We have reviewed your October 9, 2024 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in our
September 17, 2024 letter.
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 response to prior comment 1. Please further explain the nature of your
legal settlement expenses including your basis for concluding each component of this
adjustment is consistent with the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations. Given your growth strategy to increase your restaurants, it
appears that pre-opening expenses are normal, recurring, cash operating expenses
necessary to operate your core business. Please revise or advise.
October 22, 2024
Page 2
Please contact Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Jay Gilmore