SEC Comment Letter 0000000000-23-007816 to Lulu's Fashion Lounge Holdings, Inc. (LVLU) (CIK 0001780201) (LVLU)
Lulu's Fashion Lounge Holdings, Inc. (LVLU) (CIK 0001780201)
Date: July 21, 2023 · CIK: 0001780201 · Accession: 0000000000-23-007816
AI Filing Summary & Sentiment
File numbers found in text: 001-41059
Letter
United States securities and exchange commission logo July 21, 2023 Tiffany R. Smith Chief Financial Officer Lulu's Fashion Lounge Holdings, Inc. 195 Humboldt Avenue Chico CA 95928 Re:Lulu's Fashion Lounge Holdings, Inc. Form 10-K for Fiscal Year Ended January 1, 2023 Filed March 14, 2023 File No. 001-41059 Dear Tiffany R. Smith: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Our comment asks you to provide us with information so we may better understand your disclosure. Please respond to this 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 this comment, we may have additional comments. Form 10-K for Fiscal Year Ended January 1, 2023 Management’s Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources Cash Flow Analysis Operating Activities, page 64 1.It is not clear how your disclosure concisely explains the decrease in operating cash flows between the fiscal periods presented. Your disclosure references net income, non-cash items, and changes in operating assets and liabilities, and repeats changes disclosed in the statements of cash flows. Note that references to these items may not provide a sufficient basis to understand how operating cash actually was affected between periods. Your discussion should be a comparative analysis between periods that discusses all material factors that actually affected operating cash. Also, your analysis should discuss the reasons for underlying factors cited, particularly in regard to changes for which the impact on cash is not readily apparent. Please revise your disclosure as appropriate. Refer to
FirstName LastNameTiffany R. Smith Comapany NameLulu's Fashion Lounge Holdings, Inc. July 21, 2023 Page 2 FirstName LastName Tiffany R. Smith Lulu's Fashion Lounge Holdings, Inc. July 21, 2023 Page 2 Item 303(b) of Regulation S-K, the introductory paragraph of section IV.B and B.1 of Release No. 33-8350 for guidance, and section 501.04 of our Codification of Financial Reporting Releases regarding quantification of variance factors. Consider the preceding in regard to the analysis of changes in operating cash flows for interim periods (e.g., for the fiscal period ended April 2, 2023). In closing, 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 Patrick Kuhn at (202) 551-3308 or Doug Jones at (202) 551-3309 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
July 21, 2023
Tiffany R. Smith
Chief Financial Officer
Lulu's Fashion Lounge Holdings, Inc.
195 Humboldt Avenue
Chico CA 95928
Re:Lulu's Fashion Lounge Holdings, Inc.
Form 10-K for Fiscal Year Ended January 1, 2023
Filed March 14, 2023
File No. 001-41059
Dear Tiffany R. Smith:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. Our comment asks you to provide us with
information so we may better understand your disclosure.
Please respond to this 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 this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended January 1, 2023
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Cash Flow Analysis
Operating Activities, page 64
1.It is not clear how your disclosure concisely explains the decrease in operating cash flows
between the fiscal periods presented. Your disclosure references net income, non-cash
items, and changes in operating assets and liabilities, and repeats changes disclosed in the
statements of cash flows. Note that references to these items may not provide a sufficient
basis to understand how operating cash actually was affected between periods. Your
discussion should be a comparative analysis between periods that discusses all material
factors that actually affected operating cash. Also, your analysis should discuss the
reasons for underlying factors cited, particularly in regard to changes for which the impact
on cash is not readily apparent. Please revise your disclosure as appropriate. Refer to
FirstName LastNameTiffany R. Smith
Comapany NameLulu's Fashion Lounge Holdings, Inc.
July 21, 2023 Page 2
FirstName LastName
Tiffany R. Smith
Lulu's Fashion Lounge Holdings, Inc.
July 21, 2023
Page 2
Item 303(b) of Regulation S-K, the introductory paragraph of section IV.B and B.1 of
Release No. 33-8350 for guidance, and section 501.04 of our Codification of Financial
Reporting Releases regarding quantification of variance factors. Consider the preceding
in regard to the analysis of changes in operating cash flows for interim periods (e.g., for
the fiscal period ended April 2, 2023).
In closing, 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 Patrick Kuhn at (202) 551-3308 or Doug Jones at (202) 551-3309 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services