TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo January 19, 2022 Leanne Cunningham Chief Financial Officer Brown-Forman Corporation 850 Dixie Highway Louisville, Kentucky 40210 Re: Brown-Forman Corporation Form 10-K for the Fiscal Year Ended April 30, 2021 Filed June 21, 2021 File No. 001-00123 Dear Ms. Cunningham: We have reviewed your December 21, 2021 response to our comment letter and have the following comment. Please respond to this comment 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 our comment apply to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our reference to prior comment is to comment in our November 18, 2021 letter. Form 10-K for the Fiscal Year Ended April 30, 2021 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 31 1. We note your response to comment 1. As part of the description of the estimated net change in distributor inventories, please clearly disclose how the percentages are calculated and how to interpret positive and negative changes. Leanne Cunningham FirstName LastNameLeanne Brown-Forman Corporation Cunningham Comapany January 19,NameBrown-Forman 2022 Corporation January Page 2 19, 2022 Page 2 FirstName LastName You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Andrew Blume, Staff Accountant, at 202-551-3254 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing