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United States securities and exchange commission logo
November 29, 2021
Jennifer Ryu
Executive Vice President and Chief Financial Officer
Resources Connection, Inc.
17101 Armstrong Avenue
Irvine, CA 92614
Re: Resources
Connection, Inc.
Form 10-K for
Fiscal Year Ended May 29, 2021
Filed July 23, 2021
File No. 000-32113
Dear Ms. Ryu:
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-K for the Fiscal Year Ended May 29, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations
Operating Results of Segment, page 34
1. Please include a
discussion and analysis of all material costs and expenses attributable to
your reportable
segments that are not included in computing the segment measure of
adjusted EBITDA, for
example, depreciation and amortization. Refer to Question
104.02 of the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations
for further guidance.
2. Please revise your
disclosures here and in your earnings press releases to discuss net
income margin with
equal or greater prominence than adjusted EBITDA margin. 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.
Jennifer Ryu
Resources Connection, Inc.
November 29, 2021
Page 2
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 Stephen Kim at 202-551-3291 or Theresa Brillant at
202-551-3307 with
any questions.
FirstName LastNameJennifer Ryu Sincerely,
Comapany NameResources Connection, Inc.
Division of
Corporation Finance
November 29, 2021 Page 2 Office of Trade &
Services
FirstName LastName