TPRTapestry, Inc.

Your narrative of the year-to-year fluctuations, in the summary and segment performance sections, consistently use the phrase “excluding non-GAAP charges” to refer to the expenses incurred for ERP implementation, integration and acquisition, and the impact of the tax legislation that you excluded as adjustments in your GAAP to Non-GAAP reconciliation.

Rest of the question

It appears to us that your use of this phrase may be confusing to an investor since the items you are excluding are not non-GAAP charges, but rather certain significant items affecting the comparability of your results of operations. Please revise future filings to eliminate the use of the term “non-GAAP charges” where you discuss the results of operations between periods, and characterize the nature of such charges differently. 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.

We acknowledge the Staff’s comment and confirm that in future filings we will eliminate the use of the term “non-GAAP charges” when discussing results of operations between periods. We will instead reference these charges as “items affecting comparability” or other similar terminology.

As stated in the comment letter, we hereby acknowledge that the Company is responsible for the accuracy and adequacy of the disclosure in our filings. Read in the reply ↗