SecProbe.io

December 2, 2025
William G. Barton
President & Chief Executive Officer
Bob's Discount Furniture, Inc.
434 Tolland Turnpike
Manchester, CT 06042
Re:Bob's Discount Furniture, Inc.
Draft Registration Statement on Form S-1
Submitted September 19, 2025
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted November 5, 2025
CIK No. 002085187
Dear William G. Barton:
            We have reviewed your draft registration statement and your amendment to your draft
registration statement and have the following comment(s).
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement and non-public draft submissions on EDGAR. If you do not believe a comment
applies to your facts and circumstances or do not believe an amendment is appropriate, please
tell us why in your response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1
The Offering, page 17
Where you discuss the use of proceeds, quantify the amount that will be used to repay
the Term Loan Facility, and specify that borrowings under the Term Loan Facility
were used to pay the cash dividend to pre-IPO stockholders, including Bain Capital.
To the extent that any of the proceeds will be used to pay the cash dividend directly,
please also quantify this amount. Elsewhere that you discuss the Term Loan Facility,
explain that you are obligated to prepay the outstanding amount with 100% of the net
cash proceeds upon consummation of the IPO, as disclosed on page 125. If any 1.

December 2, 2025
Page 2
amount will remain outstanding under the Term Loan Facility following the IPO such
that you will be obligated to use 50% of annual excess cash flow (subject to a step-
down) to prepay the outstanding amount, disclose this as well. Include related risk
factor disclosure, as appropriate.
Summary Historical Consolidated Financial Data, page 18
2.Please revise your pro forma weighted average number of shares outstanding
computation (discussed in note 1) to limit the number of IPO shares included to
specific and appropriate use of proceeds items, such as the number of shares used to
repay debt.
3.Please revise the comparable sales growth title to refer to it as adjusted on pages 20
and 60, and anywhere else as adjusted amounts are presented. Also, present
comparable sales growth unadjusted whenever as adjusted amounts are presented.
Our business, results of operations and financial condition may be adversely affected by
global economic conditions and the effect of..., page 22
4.We note your disclosure on page 75 that you continue to be impacted by inflation,
including in the nine-month fiscal period ended September 28, 2025. Please
update this risk factor and Management's Discussion and Analysis to explain how
inflationary pressures have materially impacted your operations. In this regard, please
identify the types of inflationary pressures you are facing and clarify the resulting
impact(s) to the company and on your results of operations. Please also discuss any
mitigating factors you have taken, or may take, in response to inflation, such as price
increases which you discuss on page 75. We also note that you experienced declines
in comparable sales in both 2023 and 2024, which you attribute partially to inflation.
To the extent material, please explain whether there is a risk that your recent
comparable sales growth could be impacted by inflation.
Risks Related to Data Privacy and Information Technology
We rely extensively on computer systems to process transactions, summarize results and
manage our business. Disruptions in both our..., page 37
5.We note the inclusion of disclosure throughout referring to a system outage in 2024.
Please update this risk factor to address this outage and the related insurance
coverage, if material.
Certain of our directors may have conflicts..., page 44
6.Please discuss here or in a separate risk factor the possible conflicts of interest that
stem from management's decision to enter into $350 million term loan agreement to
pay a $423.3 million pre-IPO dividend to existing shareholders, including the majority
shareholder Bain Capital.
General
Please supplementally provide us with copies of all written communications, as
defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so
on your behalf, present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not they retain copies of the communications. Please 7.

December 2, 2025
Page 3
contact the staff member associated with the review of this filing to discuss how to
submit the materials, if any, to us for our review.
            Please contact Ta Tanisha Meadows at 202-551-3322 or Rufus Decker at 202-551-
3769 if you have questions regarding comments on the financial statements and related
matters. Please contact Nicholas Nalbantian at 202-551-7470 or Erin Jaskot at 202-551-3442
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Craig E. Marcus