SEC Comment Letter for DULUTH HOLDINGS INC. (DLTH) (CIK 0001649744) (DLTH) — Dec 13, 2016
DULUTH HOLDINGS INC. (DLTH) (CIK 0001649744)
Date: Dec. 13, 2016 · CIK: 0001649744 · Accession: 0000000000-16-104646
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 December 13 , 2016 Via Email Mr. Mark M. DeOrio Senior Vice President and Chief Financial Officer Duluth Holdings Inc . 170 Countryside Drive P.O. Box 409 Belleville, Wisconsin 53508
Re: Duluth Holdings Inc. Form 10-K for Fiscal Year Ended January 31, 2016 Filed April 8, 2016 File No. 1 -37641
Dear Mr. DeOrio :
We have reviewed your filing an d 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 this comment within ten busine ss days by providing the requested information or advis e 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 this comment , we may have additional comments.
Form 10 -K for Fiscal Year Ended January 31, 2016
Consolidated Financial Statements Note 7. Segment Reporting, page 62
1. On page 8, you discuss your product assortment. Please disclose in a footnote your revenues from external customers by product for each period presented as required by ASC 280 -10-50-40.
Mr. Mark M. DeOrio Duluth Holdings Inc. December 13 , 2016 Page 2
We remind you that the company and i ts management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or a bsence of action by the staff.
You may contact Linda Cvrkel at (202) 551 -3813 or me at (202) 551 -3769 with any questions.
Sincerely,
/s/ Rufus Decker
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Mail Stop 3561 December 13 , 2016 Via Email Mr. Mark M. DeOrio Senior Vice President and Chief Financial Officer Duluth Holdings Inc . 170 Countryside Drive P.O. Box 409 Belleville, Wisconsin 53508 Re: Duluth Holdings Inc. Form 10-K for Fiscal Year Ended January 31, 2016 Filed April 8, 2016 File No. 1 -37641 Dear Mr. DeOrio : We have reviewed your filing an d 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 this comment within ten busine ss days by providing the requested information or advis e 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 this comment , we may have additional comments. Form 10 -K for Fiscal Year Ended January 31, 2016 Consolidated Financial Statements Note 7. Segment Reporting, page 62 1. On page 8, you discuss your product assortment. Please disclose in a footnote your revenues from external customers by product for each period presented as required by ASC 280 -10-50-40. Mr. Mark M. DeOrio Duluth Holdings Inc. December 13 , 2016 Page 2 We remind you that the company and i ts management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or a bsence of action by the staff. You may contact Linda Cvrkel at (202) 551 -3813 or me at (202) 551 -3769 with any questions. Sincerely, /s/ Rufus Decker Rufus Decker Accounting Branch Chief Office of Beverages, Apparel and Mining