SEC Comment Letter 0000000000-23-006569 to Wingstop Inc. (WING) (CIK 0001636222) (WING)
Wingstop Inc. (WING) (CIK 0001636222)
Date: June 20, 2023 · CIK: 0001636222 · Accession: 0000000000-23-006569
AI Filing Summary & Sentiment
File numbers found in text: 001-37425
Letter
United States securities and exchange commission logo June 20, 2023 Michael Skipworth President and Chief Executive Officer Wingstop Inc. 15505 Wright Brothers Drive Addison, Texas 75001 Re:Wingstop Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Response dated June 14, 2023 File No. 001-37425 Dear Michael Skipworth: We have reviewed your June 14, 2023 response to our comment letter 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 our 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 our comment, we may have additional comments. Unless we note otherwise, our references to prior comment is to the comment in our June 2, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Key Performance Indicators, page 31 1.We read your response to comment 1. It appears to us that the strategic initiatives to develop a long-term supply chain and conduct market analysis of industry landscape and consumer demand represent regular operating activities to run your business as a restaurant chain. Therefore, the consulting fees incurred relating to these activities appear to be normal, cash operating expenses necessary for your revenue-generating activities and business strategy. As such, please remove the adjustment for consulting fees from your non-GAAP measure reconciliations. Refer to Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameMichael Skipworth Comapany NameWingstop Inc. June 20, 2023 Page 2 FirstName LastName Michael Skipworth Wingstop Inc. June 20, 2023 Page 2 You may contact Suying Li at (202) 551-3335 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
June 20, 2023
Michael Skipworth
President and Chief Executive Officer
Wingstop Inc.
15505 Wright Brothers Drive
Addison, Texas 75001
Re:Wingstop Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Response dated June 14, 2023
File No. 001-37425
Dear Michael Skipworth:
We have reviewed your June 14, 2023 response to our comment letter 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 our 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 our comment, we may have additional
comments. Unless we note otherwise, our references to prior comment is to the comment in our
June 2, 2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Performance Indicators, page 31
1.We read your response to comment 1. It appears to us that the strategic initiatives to
develop a long-term supply chain and conduct market analysis of industry landscape and
consumer demand represent regular operating activities to run your business as a
restaurant chain. Therefore, the consulting fees incurred relating to these activities appear
to be normal, cash operating expenses necessary for your revenue-generating activities
and business strategy. As such, please remove the adjustment for consulting fees from
your non-GAAP measure reconciliations. Refer to Question 100.01 of the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameMichael Skipworth
Comapany NameWingstop Inc.
June 20, 2023 Page 2
FirstName LastName
Michael Skipworth
Wingstop Inc.
June 20, 2023
Page 2
You may contact Suying Li at (202) 551-3335 or Rufus Decker at (202) 551-3769 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services