RE: | Delta Apparel, Inc. File No. 001-15583 Form 10-K for the year ended July 1, 2006 |
1. | We note your response to prior comment 3. Disclosure which includes statements such as “we believe it provides a more complete understanding of our business”, “we believe it is useful for investors to assess the operating performance of the business without the effect of these transactions” we do not believe demonstrate the usefulness of the non-GAAP measure. In future filings when addressing each of the disclosure requirements set forth in Question 8 of Frequently Asked Questions Regarding Use of Non-GAAP Financial Measures, provide a robust, comprehensive discussion tailored specifically to your Company and your situation, complete with substantive disclosure. Show us what your disclosure will look like revised. | |
Response to Comment 1 | ||
The non-GAAP disclosure used in the Form 10-K for the fiscal year ended July 1, 2006 was a non-GAAP measure relating to our 2005 fiscal year. As such, we will not be reporting this non-GAAP measure in future filings. In addition, we do not currently intend to use other non-GAAP measures in future filings. If, however, we do use a non-GAAP measure in future filings, we will provide a robust, comprehensive and substantive discussion tailored to our Company and our situation. |
2. | We note your response to prior comment 6 and found the Company’s response to be informative. In addition to providing the accounts receivable reconciliation please enhance your accounts receivable |
disclosure by incorporating your response regarding the terms and accounting of the agreement into the discussion. | ||
Response to Comment 2 | ||
Our discussion of accounts receivable will be supplemented accordingly in future filings. |