Tootsie Roll Industries, Inc
7401 SOUTH CICERO AVENUE • CHICAGO, ILLINOIS 60629 • (773) 838-3400
FAX (773) 838-3534
August 27, 2024
VIA EDGAR
Ms. Amanda Ravitz
Division of Corporate Finance
Securities and Exchange Commission
100F Street, NE
Washington, D.C. 20549
Re: | Comment Letter Dated August 9, 2024 | |
| Tootsie Roll Industries, Inc. | |
| Definitive Proxy Statement on Schedule 14A | |
| Filed March 25, 2024 | |
| File No. 001-01361 | |
Dear Ms. Ravitz:
We respectfully submit the following responses to your comments in the subject letter. Should you have any questions or need additional information, please do not hesitate to contact me at bbowen@tootsie-roll.com or (773) 838-3431.
Definitive Proxy Statement on Schedule 14A
Pay v Performance, page 18
| 1. | Instead of net earnings, you use a figure that deducts earnings attributable to non-controlling interests. Please confirm that, in future filings, you will use net earnings (loss) without such a deduction. |
Response: Confirmed – the reported amount in the table will be net earnings. A reconciliation of this figure to how Tootsie Roll otherwise reports net earnings for other purposes may be provided as a supplement to this disclosure.
| 2. | Please confirm that, in future filings, you will amend the header in the pay versus performance chart to indicate that you have only one Company-Selected Measure. |
Response: Confirmed. The term “Company Selected Measure” will only be over one column to the Summary Compensation Table.
| 3. | Please confirm that, in future filings, you will provide a comparison of your cumulative total shareholder return and the cumulative total shareholder return of your peer group over the same period. |
Response: Confirmed.
The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, actions or absence of actions by Commission staff.
Sincerely,
TOOTSIE ROLL INDUSTRIES, INC.
/s/ Barry Bowen
Barry Bowen
Treasurer