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United States securities and exchange commission logo
August 24, 2022
Christopher Meyer
Chief Financial Officer
Bloomin' Brands, Inc.
2202 North West Shore Boulevard, Suite 500
Tampa, FL 33607
Re: Bloomin' Brands,
Inc.
Form 10-K for the
Fiscal Year Ended December 26, 2021
Filed February 23,
2022
File No. 001-35625
Dear Mr. Meyer:
We have reviewed your filing 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-K for the Fiscal Year Ended December 26, 2021
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Financial Highlights, page 33
1. We note your disclosure
of Restaurant-level operating margin as a key financial
performance indicator.
This measure is not identified as a non-GAAP financial measure.
Tell us your
consideration of labeling this measure as a non-GAAP measure.
Additionally, please
present the most directly comparable GAAP measures with equal or
greater prominence.
Refer to Item 10(e)(1)(i)(a) of Regulation S-K and Question 102.10
of the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations. This
comment also applies to
your earning releases filed under Form 8-K.
Results of Operations, page 42
2. We note that FICA
tax credits on certain employees tips impact your effective tax rate
significantly on an
annual basis. Please discuss both the nature and drivers (e.g.,
Christopher Meyer
Bloomin' Brands, Inc.
August 24, 2022
Page 2
restaurant sales) of these tax credits. In addition, to the extent
that you experience a
significant change in your ability to utilize material tax credits in
a particular reporting
period, please disclose that fact.
Non-GAAP Financial Measures, page 44
3. We note your reconciliation on page 48. Please expand your disclosure
to clarify how you
determined the tax effect of non-GAAP adjustments in calculating
adjusted net income
(loss), adjusted diluted earnings (loss) per share, and adjustment to
provision for income
taxes in each reporting period presented. Refer to Question 102.11 of
the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations.
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 Nasreen Mohammed at 202-551-3773 or Adam Phippen at
202-551-
3336 if you have questions regarding comments on the financial statements and
related matters.
FirstName LastNameChristopher Meyer Sincerely,
Comapany NameBloomin' Brands, Inc.
Division of
Corporation Finance
August 24, 2022 Page 2 Office of
Trade & Services
FirstName LastName