United States securities and exchange commission logo
March 13, 2024
John Tyson
Chief Financial Officer
Tyson Foods, Inc.
2200 West Don Tyson Parkway
Springdale, Arkansas 72762
Re: Tyson Foods, Inc.
Form 10-K for the
Fiscal Year Ended September 30, 2023
Response Dated
March 6th, 2024
File No. 001-14704
Dear John Tyson:
We have reviewed your March 6th, 2024 response to our comment
letter and have the
following comment(s).
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our February 22,
2024 letter.
Response dated March 6th, 2024
Note 17: Segment Reporting, page 79
1. We note your response
to comment 2 indicates that "revenues from external customers for
each reportable segment
are included in the tables displaying disaggregated sales by major
distribution channel."
Although we acknowledge that investors are able to recalculate each
reportable segment's
revenues from external customers based on the information provided,
it is unclear how the
current presentation meets the explicit disclosure requirement of ASC
280-10-50-22(a). As the
combined revenue presentation in your table on page 81 is not an
ASC 280 disclosure
requirement, please revise your presentation in future filings to
separately disclose
revenues from external customers for each reportable segment.
Please contact Charles Eastman at 202-551-3794 or Andrew Blume at
202-551-3254 if
you have questions regarding comments on the financial statements and
related matters.
John Tyson
Tyson Foods, Inc.
March 13, 2024
Page 2
FirstName LastNameJohn Tyson Sincerely,
Comapany NameTyson Foods, Inc.
Division of Corporation Finance
March 13, 2024 Page 2 Office of Manufacturing
FirstName LastName