SEC Comment Letter for O REILLY AUTOMOTIVE INC (ORLY) (CIK 0000898173) (ORLY) — Dec 21, 2021
O REILLY AUTOMOTIVE INC (ORLY) (CIK 0000898173)
Date: Dec. 21, 2021 · CIK: 0000898173 · Accession: 0000000000-21-015225
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File numbers found in text: 000-21318
Letter
United States securities and exchange commission logo December 21, 2021 Gregory D. Johnson Chief Executive Officer and Co-President O’Reilly Automotive, Inc. 233 South Patterson Avenue Springfield, Missouri 65802 Re:O’Reilly Automotive, Inc. Form 10-K for the Fiscal Year Ended December 31, 2020 Filed February 26, 2021 File No. 000-21318 Dear Mr. Johnson: We have reviewed your filing 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 December 31, 2020 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Overview, page 26 1.Please tell us your consideration of reporting revenue by product and services, or groups of similar products and services, such as undercar hard parts and appearance and accessories, pursuant to ASC 280-10-50-40.
FirstName LastNameGregory D. Johnson Comapany NameO’Reilly Automotive, Inc. December 21, 2021 Page 2 FirstName LastName Gregory D. Johnson O’Reilly Automotive, Inc. December 21, 2021 Page 2 Item 8. Financial Statements and Supplementary Data Note 1. Summary of Significant Accounting Policies Litigation accruals, page 53 2.It appears based on your disclosure that you only accrue for litigation losses that are material. Please tell us and revise your disclosure to clarify that your litigation accrual policy is in accordance with ASC 450-20-25-2. 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 Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551- 3307 if you have questions regarding the comments. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 21, 2021
Gregory D. Johnson
Chief Executive Officer and Co-President
O’Reilly Automotive, Inc.
233 South Patterson Avenue
Springfield, Missouri 65802
Re:O’Reilly Automotive, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed February 26, 2021
File No. 000-21318
Dear Mr. Johnson:
We have reviewed your filing 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 December 31, 2020
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Overview, page 26
1.Please tell us your consideration of reporting revenue by product and services, or groups
of similar products and services, such as undercar hard parts and appearance and
accessories, pursuant to ASC 280-10-50-40.
FirstName LastNameGregory D. Johnson
Comapany NameO’Reilly Automotive, Inc.
December 21, 2021 Page 2
FirstName LastName
Gregory D. Johnson
O’Reilly Automotive, Inc.
December 21, 2021
Page 2
Item 8. Financial Statements and Supplementary Data
Note 1. Summary of Significant Accounting Policies
Litigation accruals, page 53
2.It appears based on your disclosure that you only accrue for litigation losses that are
material. Please tell us and revise your disclosure to clarify that your litigation accrual
policy is in accordance with ASC 450-20-25-2.
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 Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-
3307 if you have questions regarding the comments.
Sincerely,
Division of Corporation Finance
Office of Trade & Services