SEC Comment Letter for CRACKER BARREL OLD COUNTRY STORE, INC (CBRL) (CIK 0001067294) (CBRL) — Feb 5, 2020
CRACKER BARREL OLD COUNTRY STORE, INC (CBRL) (CIK 0001067294)
Date: Feb. 5, 2020 · CIK: 0001067294 · Accession: 0000000000-20-001140
AI Filing Summary & Sentiment
File numbers found in text: 001-25225
Letter
February 5, 2020 Jill Golder Chief Financial Officer Cracker Barrel Old Country Store, Inc 305 Hartmann Drive Lebanon, Tennessee 37087-4779 Re:Cracker Barrel Old Country Store, Inc Form 10-K for the Fiscal Year Ended August 2, 2019 Filed September 27, 2019 File No. 001-25225 Dear Ms. Golder: We have limited our review of your filing to the financial statements and related disclosures 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 August 2, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Key Performance Indicators, page 28 1.Please tell us how you have complied with the disclosure guidance in Item 10(e)(i) of Regulation S-K related to your presentation of store operating margins. Consolidated Statements of Income, page 45 2.Please tell us your consideration of the guidance in Item 10(e)(ii)(C) of Regulation S-K related to your presentation of store operating income on the face of the statements of income. In closing, 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 LastNameJill Golder Comapany NameCracker Barrel Old Country Store, Inc February 5, 2020 Page 2 FirstName LastName Jill Golder Cracker Barrel Old Country Store, Inc February 5, 2020 Page 2 You may contact Tony Watson at (202) 551-3318 or Bill Thompson at (202) 551-3344 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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February 5, 2020
Jill Golder
Chief Financial Officer
Cracker Barrel Old Country Store, Inc
305 Hartmann Drive
Lebanon, Tennessee 37087-4779
Re:Cracker Barrel Old Country Store, Inc
Form 10-K for the Fiscal Year Ended August 2, 2019
Filed September 27, 2019
File No. 001-25225
Dear Ms. Golder:
We have limited our review of your filing to the financial statements and related
disclosures 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 August 2, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Performance Indicators, page 28
1.Please tell us how you have complied with the disclosure guidance in Item 10(e)(i) of
Regulation S-K related to your presentation of store operating margins.
Consolidated Statements of Income, page 45
2.Please tell us your consideration of the guidance in Item 10(e)(ii)(C) of Regulation S-K
related to your presentation of store operating income on the face of the statements of
income.
In closing, 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 LastNameJill Golder
Comapany NameCracker Barrel Old Country Store, Inc
February 5, 2020 Page 2
FirstName LastName
Jill Golder
Cracker Barrel Old Country Store, Inc
February 5, 2020
Page 2
You may contact Tony Watson at (202) 551-3318 or Bill Thompson at (202) 551-3344
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services