SEC Comment Letter 0000000000-23-000620 to Dave & Buster's Entertainment, Inc. (PLAY) (CIK 0001525769) (PLAY)
Dave & Buster's Entertainment, Inc. (PLAY) (CIK 0001525769)
Date: Jan. 19, 2023 · CIK: 0001525769 · Accession: 0000000000-23-000620
AI Filing Summary & Sentiment
File numbers found in text: 001-35664
Letter
United States securities and exchange commission logo January 19, 2023 Michael Quartieri Chief Financial Officer Dave & Buster's Entertainment, Inc. 1221 Beltline Rd. Coppell, TX 75019 Re:Dave & Buster's Entertainment, Inc. Form 10-K for the Fiscal Year Ended January 30, 2022 Filed March 29, 2022 File No. 001-35664 Dear Michael Quartieri: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended January 30, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Fiscal 2021 Compared to Fiscal 2020 Reconciliations of Non-GAAP Financial Measures Adjusted EBITDA, page 38 1.Adjusted EBITDA appears to be a company-level non-GAAP measure, rather than a store-level non-GAAP measure, like store operating income before depreciation and amortization. Please remove the pre-opening expenses adjustment from Adjusted EBITDA, as it appears to represent normal, recurring, cash operating expenses necessary to operate your business. Refer to Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameMichael Quartieri Comapany NameDave & Buster's Entertainment, Inc. January 19, 2023 Page 2 FirstName LastName Michael Quartieri Dave & Buster's Entertainment, Inc. January 19, 2023 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. You may contact Keira Nakada at 202-551-3659 or Rufus Decker at 202-551-3769 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
January 19, 2023
Michael Quartieri
Chief Financial Officer
Dave & Buster's Entertainment, Inc.
1221 Beltline Rd.
Coppell, TX 75019
Re:Dave & Buster's Entertainment, Inc.
Form 10-K for the Fiscal Year Ended January 30, 2022
Filed March 29, 2022
File No. 001-35664
Dear Michael Quartieri:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to the comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended January 30, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Fiscal 2021 Compared to Fiscal 2020
Reconciliations of Non-GAAP Financial Measures
Adjusted EBITDA, page 38
1.Adjusted EBITDA appears to be a company-level non-GAAP measure, rather than a
store-level non-GAAP measure, like store operating income before depreciation and
amortization. Please remove the pre-opening expenses adjustment from Adjusted
EBITDA, as it appears to represent normal, recurring, cash operating expenses necessary
to operate your business. Refer to Question 100.01 of the Non-GAAP Financial Measures
Compliance and Disclosure Interpretations.
FirstName LastNameMichael Quartieri
Comapany NameDave & Buster's Entertainment, Inc.
January 19, 2023 Page 2
FirstName LastName
Michael Quartieri
Dave & Buster's Entertainment, Inc.
January 19, 2023
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.
You may contact Keira Nakada at 202-551-3659 or Rufus Decker at 202-551-3769 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services