SEC Comment Letter 0000000000-24-002646 to KOHLS Corp (KSS) (CIK 0000885639) (KSS)
KOHLS Corp (KSS) (CIK 0000885639)
Date: March 11, 2024 · CIK: 0000885639 · Accession: 0000000000-24-002646
AI Filing Summary & Sentiment
File numbers found in text: 001-11084
Letter
United States securities and exchange commission logo March 11, 2024 Jill Timm Chief Financial Officer Kohl’s Corporation N56 W17000 Ridgewood Drive Menomonee Falls, Wisconsin 53051 Re:Kohl’s Corporation Form 10-K for Fiscal Year Ended January 28, 2023 File No. 001-11084 Dear Jill Timm: We have reviewed your March 6, 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 February 28, 2024 letter. Form 10-K for Fiscal Year Ended January 28, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 21 1.We note your response to prior comment 2. Please expand your disclosure regarding the use of the capital structure ratio to state that the ratio is a liquidity measure, and that it is provided to your ratings agencies. Additionally, please add a footnote to EBITDAR to explain that this component of the ratio excludes costs (i.e. rent) that are essential to the operation of your stores.
FirstName LastNameJill Timm Comapany NameKohl’s Corporation March 11, 2024 Page 2 FirstName LastName Jill Timm Kohl’s Corporation March 11, 2024 Page 2 Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-3307 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 11, 2024
Jill Timm
Chief Financial Officer
Kohl’s Corporation
N56 W17000 Ridgewood Drive
Menomonee Falls, Wisconsin 53051
Re:Kohl’s Corporation
Form 10-K for Fiscal Year Ended January 28, 2023
File No. 001-11084
Dear Jill Timm:
We have reviewed your March 6, 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 February 28,
2024 letter.
Form 10-K for Fiscal Year Ended January 28, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 21
1.We note your response to prior comment 2. Please expand your disclosure regarding the
use of the capital structure ratio to state that the ratio is a liquidity measure, and that it is
provided to your ratings agencies. Additionally, please add a footnote to EBITDAR to
explain that this component of the ratio excludes costs (i.e. rent) that are essential to the
operation of your stores.
FirstName LastNameJill Timm
Comapany NameKohl’s Corporation
March 11, 2024 Page 2
FirstName LastName
Jill Timm
Kohl’s Corporation
March 11, 2024
Page 2
Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services