TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo April 2, 2024 Craig Pommells Chief Financial Officer Cracker Barrel Old Country Store, Inc. 305 Hartmann Drive Lebanon, TN 37087-4779 Re: Cracker Barrel Old Country Store, Inc. Form 10-K for the Fiscal Year Ended July 28, 2023 Form 8-K Filed February 27, 2024 Response dated March 20, 2024 File No. 001-25225 Dear Craig Pommells: We have reviewed your March 20, 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 March 6, 2024 letter. Form 8-K Filed February 27, 2024 Exhibit 99.1 - Press Release issued by Cracker Barrel Old Country Store, Inc. dated February 27, 2024 Adjusted Operating Income and Earnings Per Share, page 8 1. We note in your response to prior comment 2 that GAAP requires recognition of the amortization expense of the asset resulting from the sale and leaseback transactions. The adjustment in question appears to have the effect of modifying the measurement and recognition principles of lease accounting for the amortization resulting from the sale and leaseback transactions. Accordingly, this adjustment appears inconsistent with Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please remove this adjustment from your non-GAAP measures or tell us why it is appropriate within the context of Question 100.04. Craig Pommells Cracker Barrel Old Country Store, Inc. April 2, 2024 Page 2 Please contact James Giugliano at 202-551-3319 or Joel Parker at 202-551-3651 if you have questions regarding comments on the financial statements and related matters. FirstName LastNameCraig Pommells Sincerely, Comapany NameCracker Barrel Old Country Store, Inc. Division of Corporation Finance April 2, 2024 Page 2 Office of Trade & Services FirstName LastName