7500 EAST COLUMBIA STREET • EVANSVILLE, INDIANA 47715 • (812) 867-6471
June 21, 2022
Division of Corporation Finance
U.S. Securities & Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attn: | Keira Nakada |
| Rufus Decker |
| Office of Trade & Services |
Re: | Shoe Carnival, Inc. |
| Form 10-K for the Fiscal Year Ended January 29, 2022 |
| Filed March 25, 2022 |
| Comment Letter dated June 14, 2022 |
| File No. 000-21360 |
Ladies and Gentlemen:
Shoe Carnival, Inc. (the “Company”) is responding to the comment letter of the Staff of the Securities and Exchange Commission (the “Staff”) dated June 14, 2022 on the above referenced filing. For your convenience, we have reproduced the Staff’s comment in bold immediately preceding the Company’s response.
Form 10-K for the Fiscal Year Ended January 29, 2022
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Fiscal 2021 Compared to Fiscal 2020, page 31
1.
Where you attribute material fluctuations in your results of operations to multiple factors, please quantify each factor cited so that investors may understand the magnitude and relative impact of each factor. In this regard, you attribute the increase in net sales to an increase in units sold and an increase in the average transaction price. Refer to Item 303(b) of Regulation S-K.
Response:
The Company acknowledges the Staff’s comment and confirms that in future filings with the Commission, to the extent the Company’s income statement presents material changes from period to period in its net sales, it will quantify the factors cited to which material changes are attributed, pursuant to the guidance included in Item 303(b) of Regulation S-K. Using the Form 10-K reviewed as a guide, such disclosure in future filings would read as follows:
“Net sales in fiscal 2021 were also favorably impacted by a 19% increase in average transaction price and a 14% increase in units sold compared to fiscal 2020, with store traffic slightly above the pre-pandemic levels experienced in fiscal 2019.”
Should you have additional questions regarding the above, please contact Kerry Jackson at (812) 867-4037 or via e-mail at kjackson@scvl.com.
Sincerely,
/s/ W. Kerry Jackson
W. Kerry Jackson
Chief Financial Officer