SEC Comment Letter 0000000000-23-004548 to Portillo's Inc. (PTLO) (CIK 0001871509) (PTLO)
Portillo's Inc. (PTLO) (CIK 0001871509)
Date: May 3, 2023 · CIK: 0001871509 · Accession: 0000000000-23-004548
AI Filing Summary & Sentiment
File numbers found in text: 001-40951
Letter
United States securities and exchange commission logo May 3, 2023 Michelle Hook Chief Financial Officer and Treasurer Portillo's Inc. 2001 Spring Road, Suite 400 Oak Brook, IL 60523 Re:Portillo's Inc. Form 10-K for Fiscal Year Ended December 25, 2022 Filed March 2, 2023 File No. 001-40951 Dear Michelle Hook: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for Fiscal Year Ended December 25, 2022 Consolidated Financial Statements Consolidated Statements of Operations, page 53 1.It appears from your disclosure on page 36 that cost of goods sold, excluding depreciation and amortization, consists primarily of food, beverages and paper products costs, and is not burdened with other direct and indirect costs of producing your food and beverages. If so, please retitle this line item accordingly to better reflect what it represents. Note 3. Revenue Recognition, page 66 2.On pages 35 and 62, you disclose that at the end of fiscal 2021, you began to record in revenues the third-party delivery menu price premiums for transactions through non- Company owned channels. Please provide us your ASC 606 analysis supporting this change in accounting treatment.
FirstName LastNameMichelle Hook Comapany NamePortillo's Inc. May 3, 2023 Page 2 FirstName LastName Michelle Hook Portillo's Inc. May 3, 2023 Page 2 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 Blaise Rhodes at 202-551-3774 or Rufus Decker at 202-551-3769 if you have questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
May 3, 2023
Michelle Hook
Chief Financial Officer and Treasurer
Portillo's Inc.
2001 Spring Road, Suite 400
Oak Brook, IL 60523
Re:Portillo's Inc.
Form 10-K for Fiscal Year Ended December 25, 2022
Filed March 2, 2023
File No. 001-40951
Dear Michelle Hook:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 25, 2022
Consolidated Financial Statements
Consolidated Statements of Operations, page 53
1.It appears from your disclosure on page 36 that cost of goods sold, excluding depreciation
and amortization, consists primarily of food, beverages and paper products costs, and is
not burdened with other direct and indirect costs of producing your food and beverages. If
so, please retitle this line item accordingly to better reflect what it represents.
Note 3. Revenue Recognition, page 66
2.On pages 35 and 62, you disclose that at the end of fiscal 2021, you began to record in
revenues the third-party delivery menu price premiums for transactions through non-
Company owned channels. Please provide us your ASC 606 analysis supporting this
change in accounting treatment.
FirstName LastNameMichelle Hook
Comapany NamePortillo's Inc.
May 3, 2023 Page 2
FirstName LastName
Michelle Hook
Portillo's Inc.
May 3, 2023
Page 2
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 Blaise Rhodes at 202-551-3774 or Rufus Decker at 202-551-3769 if
you have questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services