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
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File numbers found in text: 001-12882
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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