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United States securities and exchange commission logo
January 30, 2024
Robert Lucian
Chief Financial Officer
LA-Z-BOY INC
One La-Z-Boy Drive
Monroe, MI 48162-5138
Re: LA-Z-BOY INC
Form 10-K
Filed June 20, 2023
Form 8-K
Filed June 20,
2023, August 22, 2023 and November 29, 2023
File No. 001-09656
Dear Robert Lucian:
We have limited our review of your filings to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Forms 8-K filed June 20, 2023, August 22, 2023 and November 29, 2023
Exhibit 99.1, page 1
1. We note you present
Non-GAAP financial measures related to your Retail and Wholesale
reportable segments
that you identify as Non-GAAP Adjusted Operating Margin and Non-
GAAP Adjusted Operating
Income but you do not present the most directly comparable
GAAP measures, GAAP
segment operating margin and GAAP segment operating
income, with equal or
greater prominence. For each Non-GAAP financial measure you
present, please revise
future filings to present the most directly comparable GAAP
measure with equal or
greater prominence as required by Item 10(e)(1)(i)(A) of
Regulation S-K and
Question 102.10 of the Division of Corporation Finance s
Compliance & Disclosure
Interpretations on Non-GAAP Financial Measures.
Robert Lucian
FirstName
LA-Z-BOYLastNameRobert Lucian
INC
Comapany
January 30,NameLA-Z-BOY
2024 INC
January
Page 2 30, 2024 Page 2
FirstName LastName
2. We note you present certain Non-GAAP adjustments, such as Business
Realignment,
Mexico Optimization, and Supply Chain Optimization, but you do not
adequately explain
the specific nature of the costs included in each Non-GAAP adjustment,
such
as asset impairments, gains and losses on asset sales, accelerated
depreciation
and severance as disclosed in your periodic exchange act filings. For
each Non-GAAP
adjustment you present, please revise future filings to describe the
specific nature of the
costs included in each adjustment as required by Item 10(e)(1)(i)(B)
of Regulation S-K
and Question 100.05 of the Division of Corporation Finance s
Compliance & Disclosure
Interpretations on Non-GAAP Financial Measures.
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.
Please contact Kevin Stertzel at 202-551-3723 or Anne McConnell at
202-551-3709 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing