SEC Comment Letter for CHEESECAKE FACTORY INC (CAKE) (CIK 0000887596) (CAKE) — Dec 13, 2017
CHEESECAKE FACTORY INC (CAKE) (CIK 0000887596)
Date: Dec. 13, 2017 · CIK: 0000887596 · Accession: 0000000000-17-043350
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-20574
Letter
Mailstop 3561 December 12, 2017 Matthew E. Clark Executive Vice President and Chief Financial Officer Cheesecake Factory Incorporated 26901 Malibu Hills Road Calabasas Hills, California 91301
Re: Cheesecake Factory Incorporated Form 10-K for Fiscal Year Ended January 3, 2017 Filed March 2, 2017 File No. 000-20574
Dear Mr. Clark :
We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advi se us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2016
Notes to Consolidated Financial Statements, page 50
Note 10 . Commitments and Contingencies, page 57
1. We note that you disclose several legal matters beginning on page 58 and, in some instances, you indicate that you intend to vigorously defend the action and you have not reserved for any potential future payments in addition to the amounts accrued. In accordance with ASC 450 -20-50, please revise future filings to clearly disclose the following infor mation for your loss contingencies in aggregate or individually: (1) the amount or range of reasonably possible losses in addition to the amounts accrued or (2) a statement that the reasonably possible losses cannot be estimated or are not material to your financial statements.
Matthew E. Clark The Cheesecake Factory Incorporated December 12 , 2017 Page 2
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.
You may contact Jim Dunn at (202) 551 -3724 or me at (202) 551 -3379 with any questions.
Sincerely,
/s/ Melissa Raminpour
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Mailstop 3561 December 12, 2017 Matthew E. Clark Executive Vice President and Chief Financial Officer Cheesecake Factory Incorporated 26901 Malibu Hills Road Calabasas Hills, California 91301 Re: Cheesecake Factory Incorporated Form 10-K for Fiscal Year Ended January 3, 2017 Filed March 2, 2017 File No. 000-20574 Dear Mr. Clark : We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advi se us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10 -K for Fiscal Year Ended December 31, 2016 Notes to Consolidated Financial Statements, page 50 Note 10 . Commitments and Contingencies, page 57 1. We note that you disclose several legal matters beginning on page 58 and, in some instances, you indicate that you intend to vigorously defend the action and you have not reserved for any potential future payments in addition to the amounts accrued. In accordance with ASC 450 -20-50, please revise future filings to clearly disclose the following infor mation for your loss contingencies in aggregate or individually: (1) the amount or range of reasonably possible losses in addition to the amounts accrued or (2) a statement that the reasonably possible losses cannot be estimated or are not material to your financial statements. Matthew E. Clark The Cheesecake Factory Incorporated December 12 , 2017 Page 2 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. You may contact Jim Dunn at (202) 551 -3724 or me at (202) 551 -3379 with any questions. Sincerely, /s/ Melissa Raminpour Melissa Raminpour Branch Chief Office of Transportation and Leisure