SEC Comment Letter 0000000000-24-003547 to CRACKER BARREL OLD COUNTRY STORE, INC (CBRL) (CIK 0001067294) (CBRL)
CRACKER BARREL OLD COUNTRY STORE, INC (CBRL) (CIK 0001067294)
Date: April 2, 2024 · CIK: 0001067294 · Accession: 0000000000-24-003547
AI Filing Summary & Sentiment
File numbers found in text: 001-25225
Letter
United States securities and exchange commission logo April 2, 2024 Craig Pommells Chief Financial Officer Cracker Barrel Old Country Store, Inc. 305 Hartmann Drive Lebanon, TN 37087-4779 Re:Cracker Barrel Old Country Store, Inc. Form 10-K for the Fiscal Year Ended July 28, 2023 Form 8-K Filed February 27, 2024 Response dated March 20, 2024 File No. 001-25225 Dear Craig Pommells: We have reviewed your March 20, 2024 response to our comment letter and have the following comment(s). Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 6, 2024 letter. Form 8-K Filed February 27, 2024 Exhibit 99.1 - Press Release issued by Cracker Barrel Old Country Store, Inc. dated February 27, Adjusted Operating Income and Earnings Per Share, page 8 1.We note in your response to prior comment 2 that GAAP requires recognition of the amortization expense of the asset resulting from the sale and leaseback transactions. The adjustment in question appears to have the effect of modifying the measurement and recognition principles of lease accounting for the amortization resulting from the sale and leaseback transactions. Accordingly, this adjustment appears inconsistent with Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please remove this adjustment from your non-GAAP measures or tell us why it is appropriate within the context of Question 100.04.
FirstName LastNameCraig Pommells Comapany NameCracker Barrel Old Country Store, Inc. April 2, 2024 Page 2 FirstName LastName Craig Pommells Cracker Barrel Old Country Store, Inc. April 2, 2024 Page 2 Please contact James Giugliano at 202-551-3319 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
April 2, 2024
Craig Pommells
Chief Financial Officer
Cracker Barrel Old Country Store, Inc.
305 Hartmann Drive
Lebanon, TN 37087-4779
Re:Cracker Barrel Old Country Store, Inc.
Form 10-K for the Fiscal Year Ended July 28, 2023
Form 8-K Filed February 27, 2024
Response dated March 20, 2024
File No. 001-25225
Dear Craig Pommells:
We have reviewed your March 20, 2024 response to our comment letter and have the
following comment(s).
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our March 6,
2024 letter.
Form 8-K Filed February 27, 2024
Exhibit 99.1 - Press Release issued by Cracker Barrel Old Country Store, Inc. dated February 27,
2024
Adjusted Operating Income and Earnings Per Share, page 8
1.We note in your response to prior comment 2 that GAAP requires recognition of the
amortization expense of the asset resulting from the sale and leaseback transactions. The
adjustment in question appears to have the effect of modifying the measurement and
recognition principles of lease accounting for the amortization resulting from the sale and
leaseback transactions. Accordingly, this adjustment appears inconsistent with Question
100.04 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations. Please remove this adjustment from your non-GAAP measures or tell us
why it is appropriate within the context of Question 100.04.
FirstName LastNameCraig Pommells
Comapany NameCracker Barrel Old Country Store, Inc.
April 2, 2024 Page 2
FirstName LastName
Craig Pommells
Cracker Barrel Old Country Store, Inc.
April 2, 2024
Page 2
Please contact James Giugliano at 202-551-3319 or Joel Parker at 202-551-3651 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services