SEC Comment Letter 0000000000-24-005453 to Canada Goose Holdings Inc. (GOOS) (CIK 0001690511) (GOOS)
Canada Goose Holdings Inc. (GOOS) (CIK 0001690511)
Date: May 13, 2024 · CIK: 0001690511 · Accession: 0000000000-24-005453
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38027
Referenced dates: May 3, 2024
Letter
United States securities and exchange commission logo May 13, 2024 David Forrest General Counsel Canada Goose Holdings Inc. 250 Bowie Ave Toronto, Ontario, Canada M6E 4Y2 Re:Canada Goose Holdings Inc. Form 20-F for the Fiscal Year Ended April 2, 2023 Response Letter Dated May 3, 2024 File No. 001-38027 Dear David Forrest: We have reviewed your May 3, 2024 response to our comment letter and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our April 25, 2024 letter. Response Letter Dated May 3, 2024 Form 20-F for the Fiscal Year Ended April 2, 2023, page 63 1.We note your response to comment 3 that you will revise future filings to change the name of the non-IFRS financial measure to Free Cash Flow. Your calculation of free cash flow differs from the typical calculation of cash flows from operating activities less capital expenditures considering it also adjusts for other costs. In order to avoid potential confusion, please revise the title to adjusted free cash flow or a similar description. Refer to Question 102.07 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. In addition, we note your proposed revised disclosure describes that certain investors and analysts use this information as an indicator of cash flow and to assess the Company’s financial leverage and cash available for repayment of borrowings and other financing activities. Please revise the disclosure to more appropriately characterize the usefulness of measure to the investors, as the measure does not appear to
FirstName LastNameDavid Forrest Comapany NameCanada Goose Holdings Inc. May 13, 2024 Page 2 FirstName LastName David Forrest Canada Goose Holdings Inc. May 13, 2024 Page 2 reflect all of the Company’s cash flows including amounts classified as financing cash flows. Please contact Stephany Yang at 202-551-3167 or Claire Erlanger at 202-551-3301 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
United States securities and exchange commission logo
May 13, 2024
David Forrest
General Counsel
Canada Goose Holdings Inc.
250 Bowie Ave
Toronto, Ontario, Canada M6E 4Y2
Re:Canada Goose Holdings Inc.
Form 20-F for the Fiscal Year Ended April 2, 2023
Response Letter Dated May 3, 2024
File No. 001-38027
Dear David Forrest:
We have reviewed your May 3, 2024 response to our comment letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in our April 25, 2024
letter.
Response Letter Dated May 3, 2024
Form 20-F for the Fiscal Year Ended April 2, 2023, page 63
1.We note your response to comment 3 that you will revise future filings to change the
name of the non-IFRS financial measure to Free Cash Flow. Your calculation of free cash
flow differs from the typical calculation of cash flows from operating activities less capital
expenditures considering it also adjusts for other costs. In order to avoid potential
confusion, please revise the title to adjusted free cash flow or a similar description. Refer
to Question 102.07 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures. In addition, we note your proposed revised disclosure describes that
certain investors and analysts use this information as an indicator of cash flow and to
assess the Company’s financial leverage and cash available for repayment of borrowings
and other financing activities. Please revise the disclosure to more appropriately
characterize the usefulness of measure to the investors, as the measure does not appear to
FirstName LastNameDavid Forrest
Comapany NameCanada Goose Holdings Inc.
May 13, 2024 Page 2
FirstName LastName
David Forrest
Canada Goose Holdings Inc.
May 13, 2024
Page 2
reflect all of the Company’s cash flows including amounts classified as financing cash
flows.
Please contact Stephany Yang at 202-551-3167 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing