SEC Comment Letter for AUTOZONE INC (AZO) (CIK 0000866787) (AZO) — Mar 16, 2021
AUTOZONE INC (AZO) (CIK 0000866787)
Date: March 16, 2021 · CIK: 0000866787 · Accession: 0000000000-21-003159
AI Filing Summary & Sentiment
File numbers found in text: 001-10714
Letter
United States securities and exchange commission logo March 16, 2021 Jamere Jackson Chief Financial Officer AutoZone, Inc. 123 South Front Street Memphis, Tennessee 38103 Re:AutoZone, Inc. Form 10-K for the Year Ended August 29, 2020 File No. 001-10714 Filed October 26, 2020 Dear Mr. Jackson: We have limited our review of your filing to the financial statements and related disclosures 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 10-K for the Fiscal Year Ended August 29, 2020 Item 7. Managements Discussion and Analysis of Financial Condition and Results of Operations Reconciliation of Non-GAAP Financial Measures: Adjusted After-tax ROIC and Adjusted Debt to EBITDAR, page 38 1.We note that you use average debt, net of average excess cash, in the calculation of invested capital and debt, net of excess cash, in the reconciliation of adjusted debt. Please tell us how you define and calculate average excess cash and excess cash. Please also tell us your basis for presenting average debt, net of average excess cash and presenting debt, net of excess cash. 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 LastNameJamere Jackson Comapany NameAutoZone, Inc. March 16, 2021 Page 2 FirstName LastName Jamere Jackson AutoZone, Inc. March 16, 2021 Page 2 You may contact Amy Geddes at 202-551-3304 or Aamira Chaudhry at 202-551- 3389 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 16, 2021
Jamere Jackson
Chief Financial Officer
AutoZone, Inc.
123 South Front Street
Memphis, Tennessee 38103
Re:AutoZone, Inc.
Form 10-K for the Year Ended August 29, 2020
File No. 001-10714
Filed October 26, 2020
Dear Mr. Jackson:
We have limited our review of your filing to the financial statements and related
disclosures 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 10-K for the Fiscal Year Ended August 29, 2020
Item 7. Managements Discussion and Analysis of Financial Condition and Results of Operations
Reconciliation of Non-GAAP Financial Measures: Adjusted After-tax ROIC and Adjusted Debt
to EBITDAR, page 38
1.We note that you use average debt, net of average excess cash, in the calculation of
invested capital and debt, net of excess cash, in the reconciliation of adjusted debt. Please
tell us how you define and calculate average excess cash and excess cash. Please also tell
us your basis for presenting average debt, net of average excess cash and presenting debt,
net of excess cash.
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 LastNameJamere Jackson
Comapany NameAutoZone, Inc.
March 16, 2021 Page 2
FirstName LastName
Jamere Jackson
AutoZone, Inc.
March 16, 2021
Page 2
You may contact Amy Geddes at 202-551-3304 or Aamira Chaudhry at 202-551-
3389 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services