Correspondence 0001104659-23-010224 from Dave & Buster's Entertainment, Inc. (PLAY) (CIK 0001525769) (PLAY)
Dave & Buster's Entertainment, Inc. (PLAY) (CIK 0001525769)
Date: Feb. 3, 2023 · CIK: 0001525769 · Accession: 0001104659-23-010224
AI Filing Summary & Sentiment
File numbers found in text: 001-35664
Referenced dates: January 19, 2023
Letter
VIA EDGAR Securities and Exchange Commission Division of Corporate Finance Attention: Keira Nakada & Rufus Decker Office of Trade & Services 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 Ms. Nakada and Mr. Decker:
Dave & Buster’s Entertainment, Inc. (the “Company”) submits this letter in response to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated January 19, 2023, related to the Form 10-K for the fiscal year ended January 30, 2022 of the Company, filed with the Commission on March 29, 2022 (File No. 001-35664) (the “Form 10-K”). For ease of reference, we have repeated the Staff’s comment below in bold and included our response immediately below such comment.
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.
Securities Exchange Commission
Division of Corporate Finance
February 3, 2023
Page 2
Response: The Company acknowledges the Staff’s comment and will remove the pre-opening expenses from Adjusted EBITDA in future filings.
Should any questions arise in connection with the filing or this response letter, please contact the undersigned at (972) 813-1151.
Sincerely,
DAVE & BUSTER’S ENTERTAINMENT, INC.
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filename1.htm
Store Support Center
1221 S. Belt Line Rd, Suite 500
Coppell, TX 75019
daveandbusters.com
Michael Quartieri
SVP & CFO
michael.quartieri@daveandbusters.com
February 3, 2023
VIA EDGAR
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, DC 20549
Attention: Keira Nakada & Rufus Decker
Office of Trade & Services
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 Ms. Nakada and Mr. Decker:
Dave & Buster’s Entertainment, Inc. (the
“Company”) submits this letter in response to the comment of the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) contained in its letter dated January 19, 2023, related to the Form 10-K for the fiscal year
ended January 30, 2022 of the Company, filed with the Commission on March 29, 2022 (File No. 001-35664) (the “Form 10-K”).
For ease of reference, we have repeated the Staff’s comment below in bold and included our response immediately below such comment.
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.
Securities Exchange Commission
Division of Corporate Finance
February 3, 2023
Page 2
Response: The Company acknowledges the Staff’s comment
and will remove the pre-opening expenses from Adjusted EBITDA in future filings.
Should any questions arise in connection with the
filing or this response letter, please contact the undersigned at (972) 813-1151.
Sincerely,
DAVE & BUSTER’S ENTERTAINMENT, INC.
/s/ Michael Quartieri
Name: Michael Quartieri
Title: Chief Financial Officer