SEC Comment Letter 0000000000-24-004751 to CRACKER BARREL OLD COUNTRY STORE, INC (CBRL) (CIK 0001067294) (CBRL)
CRACKER BARREL OLD COUNTRY STORE, INC (CBRL) (CIK 0001067294)
Date: April 29, 2024 · CIK: 0001067294 · Accession: 0000000000-24-004751
AI Filing Summary & Sentiment
File numbers found in text: 001-25225
Letter
United States securities and exchange commission logo April 29, 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 April 16, 2024 File No. 001-25225 Dear Craig Pommells: We have reviewed your April 16, 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 [Month day, year] letter. Form 8-K Filed February 27, 2024 Exhibit 99.1 - Press Release issued by Cracker Barrel Old Country Store, Inc. dated February 27, EBITDA / Adjusted EBITDA, page 8 1.We note from your response to our prior comment that you believe the amortization of the asset recognized from the gain on sale and leaseback transactions is not reflective of your operating performance and that the Adjusted EBITDA measure provides useful information to your investors. However, your response does not address whether the adjustment results in a change in the recognition and measurement principles required to be applied in accordance with GAAP. (Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.) We therefore reissue our comment. Please remove this adjustment from all your non-GAAP measures or tell us
FirstName LastNameCraig Pommells Comapany NameCracker Barrel Old Country Store, Inc. April 29, 2024 Page 2 FirstName LastName Craig Pommells Cracker Barrel Old Country Store, Inc. April 29, 2024 Page 2 why it is appropriate within the context of Question 100.04. 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 29, 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 April 16, 2024
File No. 001-25225
Dear Craig Pommells:
We have reviewed your April 16, 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 [Month day, year]
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
EBITDA / Adjusted EBITDA, page 8
1.We note from your response to our prior comment that you believe the amortization of the
asset recognized from the gain on sale and leaseback transactions is not reflective of your
operating performance and that the Adjusted EBITDA measure provides useful
information to your investors. However, your response does not address whether the
adjustment results in a change in the recognition and measurement principles required to
be applied in accordance with GAAP. (Refer to Question 100.04 of the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations.) We therefore reissue our
comment. Please remove this adjustment from all your non-GAAP measures or tell us
FirstName LastNameCraig Pommells
Comapany NameCracker Barrel Old Country Store, Inc.
April 29, 2024 Page 2
FirstName LastName
Craig Pommells
Cracker Barrel Old Country Store, Inc.
April 29, 2024
Page 2
why it is appropriate within the context of Question 100.04.
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