UPLOAD Filing
Citi Trends Inc
Date: July 14, 2025 · CIK: 0001318484 · Accession: 0000000000-25-007402
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-41886
Letter
Re: Citi Trends, Inc. Form 10-K for Fiscal Year Ended February 1, 2025 Item 2.02 Form 8-K dated June 3, 2025 Response dated July 2, 2025 File No. 001-41886 Dear Heather Plutino:
July 14, 2025
Heather Plutino Chief Financial Officer Citi Trends, Inc. 104 Coleman Boulevard Savannah, Georgia 31408
We have reviewed your July 2, 2025 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 June 5, 2025 letter.
Item 2.02 Form 8-K dated June 3, 2025 Exhibit 99.1
1. We note your response to the second bullet point of prior comment 2. In your proposed revised disclosure, you present net income flowthrough as adjusted, which appears to be a non-GAAP measure. Please provide all of the disclosures required by Item 10(e) of Regulation S-K. Also, the most directly comparable GAAP measure to adjusted EBITDA flowthrough is net income flowthrough and not total sales. In addition, please remove your disclosures implying that a non-GAAP measure reflects operating results that are more indicative of your ongoing operating performance while improving comparability to prior and future periods than a GAAP measure. Finally, disclose the additional purpose, if any, for which your management uses the adjusted EBITDA flowthrough measure. Refer to Item 10(e)(1)(i)(B) and (D) of July 14, 2025 Page 2
Regulation S-K and Question 103.02 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you have any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> July 14, 2025 Heather Plutino Chief Financial Officer Citi Trends, Inc. 104 Coleman Boulevard Savannah, Georgia 31408 Re: Citi Trends, Inc. Form 10-K for Fiscal Year Ended February 1, 2025 Item 2.02 Form 8-K dated June 3, 2025 Response dated July 2, 2025 File No. 001-41886 Dear Heather Plutino: We have reviewed your July 2, 2025 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 June 5, 2025 letter. Item 2.02 Form 8-K dated June 3, 2025 Exhibit 99.1 1. We note your response to the second bullet point of prior comment 2. In your proposed revised disclosure, you present net income flowthrough as adjusted, which appears to be a non-GAAP measure. Please provide all of the disclosures required by Item 10(e) of Regulation S-K. Also, the most directly comparable GAAP measure to adjusted EBITDA flowthrough is net income flowthrough and not total sales. In addition, please remove your disclosures implying that a non-GAAP measure reflects operating results that are more indicative of your ongoing operating performance while improving comparability to prior and future periods than a GAAP measure. Finally, disclose the additional purpose, if any, for which your management uses the adjusted EBITDA flowthrough measure. Refer to Item 10(e)(1)(i)(B) and (D) of July 14, 2025 Page 2 Regulation S-K and Question 103.02 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769 if you have any questions. Sincerely, Division of Corporation Finance Office of Trade & Services </TEXT> </DOCUMENT>