Correspondence 0001822492-25-000037 from Hillman Solutions Corp. (HLMN) (CIK 0001822492) (HLMN)
Hillman Solutions Corp. (HLMN) (CIK 0001822492)
Date: Feb. 12, 2025 · CIK: 0001822492 · Accession: 0001822492-25-000037
AI Filing Summary & Sentiment
File numbers found in text: 001-39609
Letter
Document
February 12, 2025
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, N.E.
Washington, D.C. 20549
Attn: Dale Welcome, Staff Accountant
Jean Yu, Staff Accountant
Re: Hillman Solutions Corp.
Form 10-K for the Fiscal Year Ended December 30, 2023
Filed February 22, 2024
Form 8-K Filed November 5, 2024
File No. 001-39609
Ladies and Gentlemen:
Hillman Solutions Corp. (the “Company”) hereby acknowledges receipt of the comment letter, dated February 12, 2025, from the staff of the Securities and Exchange Commission (the “Commission”) concerning the Company’s Form 8-K Filed November 5, 2024 (the “Form 8-K”) and hereby submits this letter in response. The Staff’s comments are reprinted below and are followed by the Company’s responses.
Form 8-K filed November 5, 2024
Exhibit 99.1
Non-GAAP Financial Measures, page 8
1.We note your response to prior comment 1, however, we do not consider the adjustment for the customer bankruptcy reserve to be appropriate due to its nature and how it relates to your revenue generating activities. As previously requested, please remove the adjustment to comply with guidance outlined in Question 100.01 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non- GAAP Financial Measures.
Response: The Company acknowledges the Staff’s comment and confirms that in future filings with the Commission it will remove the customer bankruptcy reserve from its Adjusted EBITDA Calculation.
If you have any questions or additional comments concerning the foregoing, please contact me at (513) 851-4900.
Sincerely,
/s/ Robert O. Kraft
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CORRESP 1 filename1.htm Document February 12, 2025 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing 100 F Street, N.E. Washington, D.C. 20549 Attn: Dale Welcome, Staff Accountant Jean Yu, Staff Accountant Re: Hillman Solutions Corp. Form 10-K for the Fiscal Year Ended December 30, 2023 Filed February 22, 2024 Form 8-K Filed November 5, 2024 File No. 001-39609 Ladies and Gentlemen: Hillman Solutions Corp. (the “Company”) hereby acknowledges receipt of the comment letter, dated February 12, 2025, from the staff of the Securities and Exchange Commission (the “Commission”) concerning the Company’s Form 8-K Filed November 5, 2024 (the “Form 8-K”) and hereby submits this letter in response. The Staff’s comments are reprinted below and are followed by the Company’s responses. Form 8-K filed November 5, 2024 Exhibit 99.1 Non-GAAP Financial Measures, page 8 1.We note your response to prior comment 1, however, we do not consider the adjustment for the customer bankruptcy reserve to be appropriate due to its nature and how it relates to your revenue generating activities. As previously requested, please remove the adjustment to comply with guidance outlined in Question 100.01 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non- GAAP Financial Measures. Response: The Company acknowledges the Staff’s comment and confirms that in future filings with the Commission it will remove the customer bankruptcy reserve from its Adjusted EBITDA Calculation. If you have any questions or additional comments concerning the foregoing, please contact me at (513) 851-4900. Sincerely, /s/ Robert O. Kraft Robert O. Kraft Chief Financial Officer Hillman Solutions Corp.