SEC Comment Letter 0000000000-23-013159 to GOLDEN ENTERTAINMENT, INC. (GDEN) (CIK 0001071255) (GDEN)
GOLDEN ENTERTAINMENT, INC. (GDEN) (CIK 0001071255)
Date: Dec. 4, 2023 · CIK: 0001071255 · Accession: 0000000000-23-013159
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File numbers found in text: 000-24993
Letter
United States securities and exchange commission logo December 4, 2023 Blake Sartini Chief Executive Officer Golden Entertainment, Inc. 6595 S. Jones Boulevard Las Vegas, Nevada 89118 Re:Golden Entertainment, Inc. Definitive Proxy Statement on Schedule 14A Filed April 12, 2023 File No. 000-24993 Dear Blake Sartini: We have limited our review of your most recent definitive proxy statement to those issues we have addressed in our comments. Please respond to these comments by confirming that you will revise your future proxy disclosures in accordance with the topics discussed below. Definitive Proxy Statement on Schedule 14A filed April 12, 2023 Pay versus Performance, page 45 1.We note that you have included Adjusted EBITDA, a non-GAAP measure, as your Company-Selected Measure pursuant to Regulation S-K Item 402(v)(2)(vi). Please provide disclosure showing how this number is calculated from your audited financial statements, as required by Regulation S-K Item 402(v)(2)(vi). You may satisfy the disclosure requirement by a cross-reference to a different part of the definitive proxy statement; however, incorporation by reference to a separate filing will not satisfy this disclosure requirement. Please contact Alyssa Wall at 202-551-8106 or Amanda Ravitz at 202-551-3412 with any other questions. Sincerely, Division of Corporation Finance Disclosure Review Program
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United States securities and exchange commission logo
December 4, 2023
Blake Sartini
Chief Executive Officer
Golden Entertainment, Inc.
6595 S. Jones Boulevard
Las Vegas, Nevada 89118
Re:Golden Entertainment, Inc.
Definitive Proxy Statement on Schedule 14A
Filed April 12, 2023
File No. 000-24993
Dear Blake Sartini:
We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comments. Please respond to these comments by confirming that you
will revise your future proxy disclosures in accordance with the topics discussed below.
Definitive Proxy Statement on Schedule 14A filed April 12, 2023
Pay versus Performance, page 45
1.We note that you have included Adjusted EBITDA, a non-GAAP measure, as your
Company-Selected Measure pursuant to Regulation S-K Item 402(v)(2)(vi). Please
provide disclosure showing how this number is calculated from your audited financial
statements, as required by Regulation S-K Item 402(v)(2)(vi). You may satisfy the
disclosure requirement by a cross-reference to a different part of the definitive proxy
statement; however, incorporation by reference to a separate filing will not satisfy this
disclosure requirement.
Please contact Alyssa Wall at 202-551-8106 or Amanda Ravitz at 202-551-3412 with any
other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program