Correspondence 0001437749-25-000018 from Holley Inc. (HLLY)
Holley Inc.
Date: Jan. 2, 2025 · CIK: 0001822928 · Accession: 0001437749-25-000018
AI Filing Summary & Sentiment
File numbers found in text: 001-39599
Referenced dates: December 19, 2024
Letter
VIA EDGAR Division of Corporation Finance Office of Manufacturing United States Securities and Exchange Commission Re: Holley Inc. Form 10-K for the Year Ended December 31, 2023 Form 10-Q for the Quarter Ended June 30, 2024 File No. 001-39599
Dear Ms. Erlanger and Mr. Woody:
Holley Inc. (“we,” “us,” “our” or the “Company”) submits this letter in response to the comment contained in the letter from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission dated December 19, 2024, regarding the above referenced filings and has provided the below response. For convenience of reference, the comment contained in the Staff’s letter is reprinted below in italics, followed by our response.
Form 10-Q for the Quarter Ended June 30, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 29
1.
We note your response to our prior comment 1. Please revise future filings to remove the adjustment related to the strategic product rationalization charge from your Non-GAAP financial measures, as it is not presented in accordance with the guidance in Question 100.01 of the SEC Staff’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
Response:
The Company acknowledges the Staff’s comment and confirms that it will remove the adjustment related to the strategic product rationalization charge from its Non-GAAP financial measures in future filings.
* * *
If you have any questions, please contact me at 615-294-3644, or by email at jesseweaver@holley.com.
Sincerely,
HOLLEY INC.
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CORRESP 1 filename1.htm hlly20250102_corresp.htm 2445 Nashville Road Bowling Green, Kentucky 42101 Holley.com January 2, 2025 VIA EDGAR Claire Erlanger Kevin Woody Division of Corporation Finance Office of Manufacturing United States Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Holley Inc. Form 10-K for the Year Ended December 31, 2023 Form 10-Q for the Quarter Ended June 30, 2024 File No. 001-39599 Dear Ms. Erlanger and Mr. Woody: Holley Inc. (“we,” “us,” “our” or the “Company”) submits this letter in response to the comment contained in the letter from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission dated December 19, 2024, regarding the above referenced filings and has provided the below response. For convenience of reference, the comment contained in the Staff’s letter is reprinted below in italics, followed by our response. Form 10-Q for the Quarter Ended June 30, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 29 1. We note your response to our prior comment 1. Please revise future filings to remove the adjustment related to the strategic product rationalization charge from your Non-GAAP financial measures, as it is not presented in accordance with the guidance in Question 100.01 of the SEC Staff’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Response: The Company acknowledges the Staff’s comment and confirms that it will remove the adjustment related to the strategic product rationalization charge from its Non-GAAP financial measures in future filings. * * * If you have any questions, please contact me at 615-294-3644, or by email at jesseweaver@holley.com. Sincerely, HOLLEY INC. By: /s/ Jesse Weaver Name: Jesse Weaver Title: Chief Financial Officer cc: Carly Kennedy, General Counsel David Freed, Mayer Brown LLP