SecProbe.io

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 March 20, 2025

Ryan Grimsland
Executive Vice President, Chief Financial Officer
Advance Auto Parts, Inc.
4200 Six Forks Road
Raleigh, NC 27609

 Re: Advance Auto Parts, Inc.
 Form 10-K for Fiscal Year Ended December 28, 2024
 Item 2.02 Form 8-K Dated February 26, 2025
 File No. 001-16797
Dear Ryan Grimsland:

 We have reviewed your filings 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.

Form 10-K for Fiscal Year Ended December 28, 2024
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page 44

1. Please revise the other assets and liabilities, net line item to present
changes in other
 assets separately from other liabilities and further breakout any
material
 components. Please also supplementally show us the amounts included in
each of the
 revised line items for each period presented. Refer to ASC 230-10-45-7
and 45-29.
2. For material items included in net (loss) income that do not affect net
cash provided
 by operating activities and are not currently presented as separate
reconciling items
 (e.g., inventory charges of $431.5 million in 2024 and $109.5 million in
2023, etc.),
 please tell us the adjustment that they are included in. For these
material items, other
 than inventory charges, also tell us their nature and the dollar amount
for each period
 presented. Finally, present these material items as separate reconciling
items or tell us
 your basis in GAAP for combining each item with other amounts that
represent
 March 20, 2025
Page 2

 deferrals of past operating cash receipts and payments and/or accruals
of expected
 future operating cash receipts and payments. Refer to paragraphs
45-28(b), 45-29 and
 45-32 of ASC 230-10-45.
Item 2.02 Form 8-K Dated February 26, 2025
Exhibit 99.1
Advance Auto Parts Reports Fourth Quarter and Full Year 2024 Results

3. Please present and discuss comparative GAAP measures/ratios when you
present and
 discuss non-GAAP measures/ratios. In this regard, you present prior
quarter/year
 adjusted gross profit, adjusted gross profit margin, adjusted SG&A,
adjusted SG&A
 margin, adjusted operating loss, adjusted operating margin, and adjusted
loss per share
 and discuss the business reasons for changes from the prior period
without
 comparable disclosure for the GAAP measures. Refer to Item
10(e)(1)(i)(A) of
 Regulation S-K and Question 102.10(a) of the Non-GAAP Financial Measures
 Compliance and Disclosure Interpretations. In addition, in your Q4 & FY
2024
 Earnings Presentation on your website, you present YoY changes (in bps,
dollars
 and/or percent) and percentage of sales for many non-GAAP measures
without
 presenting similar disclosures for the comparable GAAP measures. Refer
to Rule
 100(a) of Regulation G. In the Earnings Presentations, also do not refer
to non-GAAP
 amounts as pro forma (e.g., pro forma cash availability, pro forma
liquidity, etc.),
 when they are not computed in accordance with Article 11 of Regulation
S-X.
4. Adjusted debt to adjusted EBITDAR ratio appears to represent a non-GAAP
valuation
 measure, rather than a performance measure. Please present this ratio
for the most
 recent valuation period only with no comparison to prior periods. In
addition, when
 you present this ratio, also present the comparable GAAP debt to net
income
 ratio. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question
102.10(a) of the
 Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
Similarly
 revise the Earnings Presentations on your website to present and discuss
GAAP debt
 to net income ratio when leverage ratio is presented and discussed on a
historical
 basis. Refer to Rule 100(a) of Regulation G.
 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.

 Please contact Keira Nakada at 202-551-3659 or Rufus Decker at
202-551-3769 if
you have any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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