Correspondence 0001104659-22-128302 from Citi Trends Inc (CTRN)
Citi Trends Inc
Date: Dec. 19, 2022 · CIK: 0001318484 · Accession: 0001104659-22-128302
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-51315
Referenced dates: December 9, 2022
Letter
Division of Corporation Finance Form 10-K for the year ended December 31, 2021 Filed April 14, 2022 Form 8-K filed November 29, 2022 File No. 000-51315
Re: Citi Trends, Inc.
Dear Ms. Cvrkel and Mr. Decker:
We hereby respond to the comment of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), as set forth in the Staff’s letter dated December 9, 2022 (the “Comment Letter”), to the above referenced filing of Citi Trends, Inc. (the “Company”). The Company has filed, via EDGAR, this letter (tagged Correspondence).
The Company has the following response to the Staff’s comment in the Comment Letter. For your convenience, we have reproduced in italics below the comment from the Comment Letter with the response following.
Form 8-K filed November 29, 2022
Exhibit 99.1
Reconciliation of GAAP Basis Operating Results to Adjusted Non-GAAP Operating Results
1. Please reconcile your non-GAAP measures to the most directly comparable GAAP measures without presenting a non-GAAP income statement. Refer to Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations..
RESPONSE:
The Company respectfully acknowledges the Staff’s comment and confirms that in future filings, it will reconcile its non-GAAP measures to the most directly comparable GAAP measures without presenting a non-GAAP income statement.
If you have any questions, please do not hesitate to contact me at 912-414-6767.
Very truly yours,
/s/ Heather Plutino
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CORRESP 1 filename1.htm December 19, 2022 U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street N.E. Washington, DC 20549 Attn: Linda Cvrkel and Rufus Decker Re: Citi Trends, Inc. Form 10-K for the year ended December 31, 2021 Filed April 14, 2022 Form 8-K filed November 29, 2022 File No. 000-51315 Dear Ms. Cvrkel and Mr. Decker: We hereby respond to the comment of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), as set forth in the Staff’s letter dated December 9, 2022 (the “Comment Letter”), to the above referenced filing of Citi Trends, Inc. (the “Company”). The Company has filed, via EDGAR, this letter (tagged Correspondence). The Company has the following response to the Staff’s comment in the Comment Letter. For your convenience, we have reproduced in italics below the comment from the Comment Letter with the response following. Form 8-K filed November 29, 2022 Exhibit 99.1 Reconciliation of GAAP Basis Operating Results to Adjusted Non-GAAP Operating Results 1. Please reconcile your non-GAAP measures to the most directly comparable GAAP measures without presenting a non-GAAP income statement. Refer to Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.. RESPONSE: The Company respectfully acknowledges the Staff’s comment and confirms that in future filings, it will reconcile its non-GAAP measures to the most directly comparable GAAP measures without presenting a non-GAAP income statement. If you have any questions, please do not hesitate to contact me at 912-414-6767. Very truly yours, /s/ Heather Plutino Heather Plutino Chief Financial Officer