SEC Comment Letter for AUTOZONE INC (AZO) (CIK 0000866787) (AZO) — May 7, 2021
AUTOZONE INC (AZO) (CIK 0000866787)
Date: May 7, 2021 · CIK: 0000866787 · Accession: 0000000000-21-005869
AI Filing Summary & Sentiment
File numbers found in text: 001-10714
Letter
United States securities and exchange commission logo May 7, 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 reviewed your March 29, 2021 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our March 16, 2021 letter. Form 10-K for the Fiscal Year Ended August 29, 2020 Item 7. Management's 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 your response to our prior comment #1. We understand that the “excess cash” arose as a result of unique circumstances related COVID-19. We further note your belief that in post-pandemic periods you do not expect to maintain excess cash and therefore do not expect to present debt or average debt, net of excess cash or average excess cash, respectively. However, it is not appropriate to present and label your amounts as “debt” and “average debt” with titles that are similar to GAAP titles. If you present these measures in future filings, please revise your disclosure accordingly. Please refer to Item 10(e)(1)(ii)(E) of Regulation S-K for further guidance.
FirstName LastNameJamere Jackson Comapany NameAutoZone, Inc. May 7, 2021 Page 2 FirstName LastName Jamere Jackson AutoZone, Inc. May 7, 2021 Page 2 You may contact Amy Geddes at 202-551-3304 or Aamira Chaudhry at 202-551-3389 if you have questions regarding comments on the financial statements and related matters, or any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
May 7, 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 reviewed your March 29, 2021 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
March 16, 2021 letter.
Form 10-K for the Fiscal Year Ended August 29, 2020
Item 7. Management's 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 your response to our prior comment #1. We understand that the “excess cash”
arose as a result of unique circumstances related COVID-19. We further note your belief
that in post-pandemic periods you do not expect to maintain excess cash and therefore do
not expect to present debt or average debt, net of excess cash or average excess cash,
respectively. However, it is not appropriate to present and label your amounts as “debt”
and “average debt” with titles that are similar to GAAP titles. If you present these
measures in future filings, please revise your disclosure accordingly. Please refer to Item
10(e)(1)(ii)(E) of Regulation S-K for further guidance.
FirstName LastNameJamere Jackson
Comapany NameAutoZone, Inc.
May 7, 2021 Page 2
FirstName LastName
Jamere Jackson
AutoZone, Inc.
May 7, 2021
Page 2
You may contact Amy Geddes at 202-551-3304 or Aamira Chaudhry at 202-551-3389 if
you have questions regarding comments on the financial statements and related matters, or any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services