February 14, 2023
Via Edgar
Hugh West
Branch Chief
U.S. Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549
Re: | LSI Industries Inc. |
Form 10-K for the fiscal year ended June 30, 2022
Filed September 9, 2022
File No. 000-13375
Dear Hugh West:
This letter responds to your letter, dated February 7, 2023, regarding our Form 10-K for the fiscal year ended June 30, 2022. Your comment is set forth below, followed by our response.
Form 10-K for the fiscal year ended June 30, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 26
1. We note that you reconcile EBITDA and Adjusted EBITDA to operating income. Please
revise your presentation in future annual and quarterly filings to reconcile these non-
GAAP measures to net income, the most directly comparable GAAP measure. Refer to
Item 10(e)(1)(i)(B) of Regulations S-K and Question 103.02 of the SEC’s Division of
Corporation Finance C&DIs on Non-GAAP Measures. This comment also applies to your
earnings releases furnished on Form 8-K.
Response: We acknowledge your comment and direction, and we will revise our presentation in future annual and quarterly reports and, as applicable, our Form 8-K reports to reconcile EBITDA and Adjusted EBITDA to net income.
You may contact me at (513) 793-3200 with any questions.
| Sincerely, |
| |
| LSI INDUSTRIES INC. | |||
|
|
|
|
|
|
|
|
| By: | /s/ James E. Galeese |
|
|
| James E. Galeese |
|
|
| Chief Financial Officer |
|
cc: F. Mark Reuter, Keating Muething & Klekamp PLL