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SEC Comment Letter for BOYD GAMING CORP (BYD) (CIK 0000906553) (BYD) — May 20, 2021

BOYD GAMING CORP (BYD) (CIK 0000906553)
Date: May 20, 2021 · CIK: 0000906553 · Accession: 0000000000-21-006409

AI Filing Summary & Sentiment

File numbers found in text: 001-12882

Date
May 20, 2021
Author
Not clearly detected
Form
UPLOAD
Company
BOYD GAMING CORP (BYD) (CIK 0000906553)

Letter

United States securities and exchange commission logo May 20, 2021 Josh Hirsberg Executive Vice President, Chief Financial Officer and Treasurer Boyd Gaming Corporation 3883 Howard Hughes Parkway, Ninth Floor Las Vegas , NV 89169 Re:Boyd Gaming Corporation Form 10-K for the year ended December 31, 2020 Filed March 1, 2021 File No. 001-12882 Dear Mr. Hirsberg: We have reviewed your filing 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 business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies 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 the year ended December 31, 2020 ITEM 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Our Key Performance Indicators, page 26 1.We note that you have identified several key performance measures to evaluate your gaming revenues. In the past few annual reports, we note that your disclosures have gone away from quantifying such measures and discussing the fluctuations and underlying contributing factors. Please clarify and/or consider revising future filings to resume discussion of these key performance measures and any material changes from period to period. 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.

FirstName LastNameJosh Hirsberg Comapany NameBoyd Gaming Corporation May 20, 2021 Page 2 FirstName LastName Josh Hirsberg Boyd Gaming Corporation May 20, 2021 Page 2 You may contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Tony McDuffie

Show Raw Text
United States securities and exchange commission logo
May 20, 2021
Josh Hirsberg
Executive Vice President, Chief Financial Officer and Treasurer
Boyd Gaming Corporation
3883 Howard Hughes Parkway, Ninth Floor
Las Vegas , NV 89169
Re:Boyd Gaming Corporation
Form 10-K for the year ended December 31, 2020
Filed March 1, 2021
File No. 001-12882
Dear Mr. Hirsberg:
            We have reviewed your filing 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 business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies 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 the year ended December 31, 2020
ITEM 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Our Key Performance Indicators, page 26
1.We note that you have identified several key performance measures to evaluate your
gaming revenues.   In the past few annual reports, we note that your disclosures have gone
away from quantifying such measures and discussing the fluctuations and underlying
contributing factors.   Please clarify and/or consider revising future filings to resume
discussion of these key performance measures and any material changes from period to
period.
            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.

 FirstName LastNameJosh Hirsberg
 Comapany NameBoyd Gaming Corporation
 May 20, 2021 Page 2
 FirstName LastName
Josh Hirsberg
Boyd Gaming Corporation
May 20, 2021
Page 2
            You may contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Tony McDuffie