SEC Comment Letter 0000000000-23-013972 to LL Flooring Holdings, Inc. (LLFLQ) (CIK 0001396033)
LL Flooring Holdings, Inc. (LLFLQ) (CIK 0001396033)
Date: Dec. 21, 2023 · CIK: 0001396033 · Accession: 0000000000-23-013972
AI Filing Summary & Sentiment
File numbers found in text: 001-33767
Letter
United States securities and exchange commission logo December 21, 2023 Robert L. Madore Chief Financial Officer LL Flooring Holdings, Inc. 4901 Bakers Mill Lane Richmond, VA 23230 Re:LL Flooring Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 File No. 001-33767 Dear Robert L. Madore: We have limited our review of your filing to the financial statements and related disclosures 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, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Net Sales, page 24 1.We note your presentation of disaggregation of revenue by product type on page 42. Please tell us what consideration was given to also including a comparative discussion of net sales based on this tabular presentation, and also by Pro versus Consumer net sales given your overall shift in strategy to focus more on Pro sales. Results of Operations Selling, General and Administrative Expenses, page 25 2.We note that the change in Adjusted SG&A of approximately $23 million is due primarily to increased investment in your growth strategies including new stores, higher marketing spend, and Pro sales, as well as competitive wage increases for customer facing associates. In addition, Adjusted SG&A deleveraged on lower net sales. Please quantify each of these changes. Refer to the guidance in Item 303(b)(2) of Regulation S-K. Please note, to the extent other line item changes are material, please identify and quantify each
FirstName LastNameRobert L. Madore Comapany NameLL Flooring Holdings, Inc. December 21, 2023 Page 2 FirstName LastName Robert L. Madore LL Flooring Holdings, Inc. December 21, 2023 Page 2 event or circumstance leading to the variance. 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. Please contact Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 21, 2023
Robert L. Madore
Chief Financial Officer
LL Flooring Holdings, Inc.
4901 Bakers Mill Lane
Richmond, VA 23230
Re:LL Flooring Holdings, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 001-33767
Dear Robert L. Madore:
We have limited our review of your filing to the financial statements and related
disclosures 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, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Net Sales, page 24
1.We note your presentation of disaggregation of revenue by product type on page 42.
Please tell us what consideration was given to also including a comparative discussion of
net sales based on this tabular presentation, and also by Pro versus Consumer net sales
given your overall shift in strategy to focus more on Pro sales.
Results of Operations
Selling, General and Administrative Expenses, page 25
2.We note that the change in Adjusted SG&A of approximately $23 million is due primarily
to increased investment in your growth strategies including new stores, higher marketing
spend, and Pro sales, as well as competitive wage increases for customer facing
associates. In addition, Adjusted SG&A deleveraged on lower net sales. Please quantify
each of these changes. Refer to the guidance in Item 303(b)(2) of Regulation S-K. Please
note, to the extent other line item changes are material, please identify and quantify each
FirstName LastNameRobert L. Madore
Comapany NameLL Flooring Holdings, Inc.
December 21, 2023 Page 2
FirstName LastName
Robert L. Madore
LL Flooring Holdings, Inc.
December 21, 2023
Page 2
event or circumstance leading to the variance.
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.
Please contact Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services