United States securities and exchange commission logo
June 10, 2024
Thomas Dineen
Chief Financial Officer
Sturm, Ruger & Company, Inc.
1 Lacey Place
Southport, CT 06890
Re: Sturm, Ruger &
Company, Inc.
Form 10-K for
Fiscal Year Ended December 31, 2023
Filed February 21,
2024
File No. 001-10435
Dear Thomas Dineen:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
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.
Form 10-K for Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations - 2023
Net Sales, Cost of Products Sold, and Gross Profit, page 25
1. You disclose here, and
in your Form 10-Q for the fiscal quarter ended March 30, 2024,
that you have
experienced inflationary cost increases in materials, commodities, services,
wages, energy, fuel,
and transportation, which have contributed to reductions in your
gross profit between
periods. Please revise your MD&A in future annual and quarterly
filings to quantify the
impact of the inflationary pressures you experience and the resulting
impact to your cost of
products sold and gross profit. In addition, expand your disclosures
in future filings to
identify actions planned or taken, if any, to mitigate inflationary
pressures.
Thomas Dineen
FirstName LastNameThomas
Sturm, Ruger & Company, Inc.Dineen
Comapany
June NameSturm, Ruger & Company, Inc.
10, 2024
June 10,
Page 2 2024 Page 2
FirstName LastName
Non-GAAP Financial Measure, page 28
2. We note that you present EBITDA margin, but do not present the most
directly
comparable GAAP measure, net income margin, with equal or greater
prominence. In
future filings, for each non-GAAP financial measure you present,
please also present the
most directly comparable GAAP measure with equal or greater prominence
in accordance
with Item 10(e)(1)(i)(A) of Regulation S-K. This comment also applies
to your Form 10-
Q for the quarterly period ended March 30, 2024, as well as to Exhibit
99.1 of your Form
8-K filed on May 7, 2024.
Schedule II - Valuation and Qualifying Accounts, page 88
3. Please remove the information relating to the Excess and obsolete
inventory reserve from
this schedule in future filings. Note that amounts recorded in
separate accounts to
recognize obsolete and slow-moving inventory are not considered
reserves for the purpose
of this schedule because those amounts in substance represent normal
adjustments /
impairment of inventory rather than true "reserves . Refer to Rule
12-09 of Regulation S-
X, SAB Topic 5.BB and ASC 330-10-35-14.
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.
Please contact Dale Welcome at 202-551-3865 or Ernest Greene at
202-551-3733 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing