April 23, 2008
H. Christopher Owings, Assistant Director
Donna Di Silvio, Senior Staff Accountant
Milwood Hobbs, Staff Accountant
Division of Corporation Finance, Mail Stop 3561
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | SUPERVALU INC. |
Form 10-K for the Fiscal Year Ended February 24, 2007 |
Filed April 25, 2007 |
Definitive Proxy Statement on Schedule 14A |
Filed May 7, 2007 |
Form 10-Q for the Fiscal Quarter Ended June 16, 2007 |
Filed July 26, 2007 |
Form 10-Q for the Fiscal Quarter Ended September 8, 2007 |
Filed October 18, 2007 |
Form 10-Q for the Fiscal Quarter Ended December 1, 2007 |
Filed January 10, 2008 |
File No.: 1-5418 |
Dear Mr. Owings:
We have received your letter dated April 18, 2008, and we appreciate your detailed comments and the questions you have provided to us outlining your request for SUPERVALU INC. to expand its enterprise-wide disclosure of products and services.
As you know, our Form 10-K is required to be filed with the Commission today. Although we are still reviewing your comments, we have significantly expanded our disclosure. We are also working on a response letter that will provide an explanation of our interpretations as well as provide additional reasoning behind the expanded disclosure included in our Form 10-K. We will file our response with you early next week.
We would of course look forward to a discussion with the Staff regarding our expanded disclosure once you have had an opportunity to review the language included in our Form 10-K and our formal response letter. If you have any questions about this matter, please feel free to call me directly at 952-828-4082 or Burt Fealing, Vice President, Corporate Secretary and Chief Securities Counsel at 952-828-4289.
Sincerely, |
/s/ Sherry M. Smith |
Sherry M. Smith |
Senior Vice President, Finance |