-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, AgdoOb32yFaJrb2531lg4gSzN8wtqywJtyemm8FpeUvZdC98KHhDKgO49WqtV6QJ H/59gU4j0uDtx0rXb13bgw== 0001193125-06-187022.txt : 20061205 0001193125-06-187022.hdr.sgml : 20061205 20060907172039 ACCESSION NUMBER: 0001193125-06-187022 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060907 FILER: COMPANY DATA: COMPANY CONFORMED NAME: LUBYS INC CENTRAL INDEX KEY: 0000016099 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-EATING PLACES [5812] IRS NUMBER: 741335253 STATE OF INCORPORATION: DE FISCAL YEAR END: 0831 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 13111 NORTHWEST FREEWAY STREET 2: SUITE 600 CITY: HOUSTON STATE: TX ZIP: 77040 BUSINESS PHONE: (713) 329 6800 MAIL ADDRESS: STREET 1: 13111 NORTHWEST FREEWAY STREET 2: SUITE 600 CITY: HOUSTON STATE: TX ZIP: 77040 FORMER COMPANY: FORMER CONFORMED NAME: LUBYS CAFETERIAS INC DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: CAFETERIAS INC DATE OF NAME CHANGE: 19810126 CORRESP 1 filename1.htm SEC Letter

Luby’s, Inc.

13111 Northwest Freeway, Suite 600

Houston, Texas 77040

September 6, 2006

Mr. Jeffrey Sears

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 

  Re: Luby’s, Inc.
       Form 8-K furnished on June 8, 2006
       File No. 001-08308

Dear Mr. Sears:

I am writing on behalf of Luby’s, Inc. (the “Company”) to respond to the comment raised by the Staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Staff”) in its letter to the Company dated June 30, 2006.

In response to the Staff’s comment regarding the use of Adjusted EBITDA, the Company plans to voluntarily suspend presenting Adjusted EBITDA in public filings made with the Commission and in press releases that are included as exhibits to such filings. The Company may continue to use Adjusted EBITDA or other non-GAAP financial measures in other documents that it does not file with or furnish to the Commission, including documents posted on its Internet website. The Company will continue to comply with the relevant rules and regulations of the Commission governing the use of non-GAAP financial measures, including Regulation G and Item 10(e) of Regulation S-K.

Representatives of the Company, its independent registered public accounting firm and its legal counsel would welcome the opportunity to address any further Staff questions or concerns either in person or by telephone if the Staff so desires.

 

Very truly yours,

/s/ Ernest Pekmezaris

Ernest Pekmezaris
Senior Vice President and Chief Financial Officer
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