SEC Company Response from AUTOZONE INC (AZO) (CIK 0000866787) (AZO) — May 14, 2021
AUTOZONE INC (AZO) (CIK 0000866787)
Date: May 14, 2021 · CIK: 0000866787 · Accession: 0001558370-21-007268
AI Filing Summary & Sentiment
File numbers found in text: 001-10714
Referenced dates: May 7, 2021
Letter
VIA EDGAR AND EMAIL United States Securities and Exchange Commission Division of Corporation Finance, Office of Trade & Services Form 10-K for Fiscal Year Ended August 29, 2020 File No. 001-10714 Filed October 26, 2020
Dear Ms. Geddes and Ms. Chaudhry,
AutoZone, Inc. (the “Company”) respectfully acknowledges receipt of and is pleased to respond to the comments from the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) on our Form 10-K for the fiscal year ended August 29, 2020. Below is our response to the comment in your letter dated May 7, 2021. For your convenience of reference and review, we have repeated your comment as presented in the letter and replied in bold immediately under the comment.
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 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.
AutoZone Response:
In future filings, the Company will not present debt or average debt, net of excess cash or average excess cash.
Please let us know if you have any further questions or if we can clarify any other issue that you may have.
Yours truly,
AutoZone, Inc.
By:/s/ JAMERE JACKSON
Jamere Jackson
Chief Financial Officer and Executive Vice President
Finance and Store Development
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CORRESP 1 filename1.htm 123 South Front Street, Memphis, TN 38103 Phone (901) 495-6500 May 14, 2021 VIA EDGAR AND EMAIL United States Securities and Exchange Commission Ms. Amy Geddes and Ms. Aamira Chaudhry Division of Corporation Finance, Office of Trade & Services 100 F Street, NE Washington, DC 20549 RE:AutoZone, Inc. Form 10-K for Fiscal Year Ended August 29, 2020 File No. 001-10714 Filed October 26, 2020 Dear Ms. Geddes and Ms. Chaudhry, AutoZone, Inc. (the “Company”) respectfully acknowledges receipt of and is pleased to respond to the comments from the Staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) on our Form 10-K for the fiscal year ended August 29, 2020. Below is our response to the comment in your letter dated May 7, 2021. For your convenience of reference and review, we have repeated your comment as presented in the letter and replied in bold immediately under the comment. 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 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. AutoZone Response: 1 In future filings, the Company will not present debt or average debt, net of excess cash or average excess cash. Please let us know if you have any further questions or if we can clarify any other issue that you may have. Yours truly, AutoZone, Inc. By:/s/ JAMERE JACKSON Jamere Jackson Chief Financial Officer and Executive Vice President Finance and Store Development 2