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United States securities and exchange commission logo
January 12, 2021
Sheila Anderson
Chief Financial Officer
DAKTRONICS INC /SD/
201 Daktronics Drive
Brookings, SD 57006
Re: DAKTRONICS INC /SD/
Form 10-K for
Fiscal Year Ended May 2, 2020
Filed June 12, 2020
Form 10-Q for
Quarterly Period Ended October 31, 2020
Filed December 3,
2020
File No. 1-38747
Dear Ms. Anderson:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-Q for the Period Ended October 31, 2020
Notes to the Condensed Consolidated Financial Statements
Note1. Basis of Presentation
Other Business Developments - Coronavirus Pandemic, page 8
1. We note your disclosure
that you offered voluntary retirement and voluntary exit incentive
programs as well as two
reductions in force during the six months ended October 31,
2020. Please tell us if
these benefits were accounted for pursuant to ASC 420 or
alternative accounting
guidance, such as ASC 712. For those pursuant to ASC 420, if
applicable, tell us
your consideration for providing the disclosures required in ASC 420-
10-50.
Sheila Anderson
FirstName LastNameSheila
DAKTRONICS INC /SD/ Anderson
Comapany
January 12,NameDAKTRONICS
2021 INC /SD/
January
Page 2 12, 2021 Page 2
FirstName LastName
Note 5. Segment Reporting, page 13
2. We note your disclosure that you evaluate segment performance based on
operating
results through contribution margin, which is comprised of gross
profit less selling
expense. We also note that you present tables for both gross profit
and contribution
margin; therefore, it appears you have presented two measures of
segment profitability. If
the chief operating decision maker uses more than one measure of a
segment s profit or
loss and more than one measure of a segment s assets, the reported
measures shall be
those that management believes are determined in accordance with the
measurement
principles most consistent with those used in measuring the
corresponding amounts in the
consolidated financial statements. In this regard, please tell us your
reportable segments
measure of profit or loss and provide an appropriate reconciliation
consistent with ASC
280-10-50-30(b).
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations
Comparison of the Three and Six Months Ended October 31, 2020 and November 2,
2019, page
23
3. We note your tables disclosing dollar amounts of Orders as well as
your disclosure of
product order backlog and your overview of backlog on page 19. We also
note similar
disclosures in your earnings releases. Please clarify how these
metrics relate to each other
and revise your disclosures to comply with the guidance in SEC Release
No. 33-10751
including providing the following for each metric:
a clear definition of the metric and how it is calculated;
a statement indicating the reasons why the metric provides useful
information to
investors, and;
a statement indicating how management uses the metric in managing
or monitoring
the performance of the business.
4. We note that in the tables on page 26 you present subtotals for
contribution margin. The
presentation of the subtotal in any context other than the ASC 280
required reconciliation
in the footnotes to the financial statements represents the
presentation of a non-GAAP
measure. Please revise your reconciliation or identify Contribution
Margin as a non-
GAAP measure and provide the disclosures required by Item 10(e) of
Regulation S-K.
Refer to Question 104.04 of the Non-GAAP Compliance and Disclosure
Interpretations.
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.
You may contact Charles Eastman, Staff Accountant at (202) 551-3794 or
Melissa
Gilmore, Staff Accountant, at (202) 551-3777 with any questions.
Sheila Anderson
DAKTRONICS INC /SD/
January 12, 2021
Page 3
FirstName LastNameSheila Anderson Sincerely,
Comapany NameDAKTRONICS INC /SD/
Division of Corporation Finance
January 12, 2021 Page 3 Office of Manufacturing
FirstName LastName