SecProbe.io

February 12, 2020
B. John Lindeman
Chief Financial Officer
CALAVO GROWERS INC
1141-A Cummings Road
Santa Paula, CA 93060
Re:CALAVO GROWERS INC
Form 10-K for the Fiscal Year Ended October 31, 2019
Filed December 19, 2019
Form 8-K Filed December 20, 2019
File No. 000-33385
Dear Mr. Lindeman:
            We have limited our review of your filing to the financial statements and related
disclosures 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 8-K filed December 20, 2019
Reconciliation of Adjusted Net Income and EPS, page 9
1.Please tell us why your adjustment (a) to eliminate the equity pickup for your investment
in FreshRealm and adjustment (e) which adds back in the losses recorded with respect to
your equity investment in Limoneira do not substitute individually-tailored income or
expense recognition methods for those of GAAP.  Refer to Question 100.04 of the
Division's Non-GAAP Financial Measures Compliance and Disclosure Interpretations.

 FirstName LastNameB. John Lindeman
 Comapany NameCALAVO GROWERS INC
 February 12, 2020 Page 2
 FirstName LastName
B. John Lindeman
CALAVO GROWERS INC
February 12, 2020
Page 2
            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.
            You may contact Christine Torney at 202-551-3652 or Mary Mast at 202-551-3613 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences