SEC Comment Letter 0000000000-24-007033 to RED ROBIN GOURMET BURGERS INC (RRGB) (CIK 0001171759) (RRGB)
RED ROBIN GOURMET BURGERS INC (RRGB) (CIK 0001171759)
Date: June 20, 2024 · CIK: 0001171759 · Accession: 0000000000-24-007033
AI Filing Summary & Sentiment
File numbers found in text: 001-34851
Letter
United States securities and exchange commission logo June 20, 2024 Todd Wilson Chief Financial Officer Red Robin Gourmet Burgers, Inc. 10000 E. Geddes Avenue, Suite 500 Englewood, CO 80112 Re:Red Robin Gourmet Burgers, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-34851 Dear Todd Wilson: We have reviewed your filing and have the following comments. 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 31, 2023 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Key Performance Indicators and Non-GAAP Financial Measures, page 26 1.Please revise to present your non-GAAP financial measures after your comparison of fiscal year results on a GAAP basis to provide equal or greater prominence to GAAP. Financial Statements 1. Description of Business and Summary of Significant Accounting Policies (c) Immaterial Restatement of Prior Period Financial Statements, page 49 2.We note you present the impacts to your "other non-GAAP information" as a result of an error correction, this would appear to be reflective of a non-GAAP measure presented in the notes to your financial statements. Refer to Item 10(e)(1)(ii)(C) of Regulation S-K. Please advise or revise to remove the measure from your future periodic and annual filings.
FirstName LastNameTodd Wilson Comapany NameRed Robin Gourmet Burgers, Inc. June 20, 2024 Page 2 FirstName LastName Todd Wilson Red Robin Gourmet Burgers, Inc. June 20, 2024 Page 2 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 Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380 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
June 20, 2024
Todd Wilson
Chief Financial Officer
Red Robin Gourmet Burgers, Inc.
10000 E. Geddes Avenue, Suite 500
Englewood, CO 80112
Re:Red Robin Gourmet Burgers, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-34851
Dear Todd Wilson:
We have reviewed your filing and have the following comments.
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 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Performance Indicators and Non-GAAP Financial Measures, page 26
1.Please revise to present your non-GAAP financial measures after your comparison of
fiscal year results on a GAAP basis to provide equal or greater prominence to GAAP.
Financial Statements
1. Description of Business and Summary of Significant Accounting Policies
(c) Immaterial Restatement of Prior Period Financial Statements, page 49
2.We note you present the impacts to your "other non-GAAP information" as a result of an
error correction, this would appear to be reflective of a non-GAAP measure presented
in the notes to your financial statements. Refer to Item 10(e)(1)(ii)(C) of Regulation S-K.
Please advise or revise to remove the measure from your future periodic and annual
filings.
FirstName LastNameTodd Wilson
Comapany NameRed Robin Gourmet Burgers, Inc.
June 20, 2024 Page 2
FirstName LastName
Todd Wilson
Red Robin Gourmet Burgers, Inc.
June 20, 2024
Page 2
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 Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380 if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services