0000068270-11-000016.txt : 20110609 0000068270-11-000016.hdr.sgml : 20110609 20110407150834 ACCESSION NUMBER: 0000068270-11-000016 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20110407 FILER: COMPANY DATA: COMPANY CONFORMED NAME: RUBY TUESDAY INC CENTRAL INDEX KEY: 0000068270 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-EATING PLACES [5812] IRS NUMBER: 630475239 STATE OF INCORPORATION: GA FISCAL YEAR END: 1007 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 150 W CHURCH ST CITY: MARYVILLE STATE: TN ZIP: 37801 BUSINESS PHONE: 2053443000 MAIL ADDRESS: STREET 1: 150 W CHURCH ST CITY: MARYVILLE STATE: TN ZIP: 37801 FORMER COMPANY: FORMER CONFORMED NAME: MORRISON RESTAURANTS INC/ DATE OF NAME CHANGE: 19930923 FORMER COMPANY: FORMER CONFORMED NAME: MORRISON RESTAURANTS INC DATE OF NAME CHANGE: 19930923 FORMER COMPANY: FORMER CONFORMED NAME: MORRISON INC /DE/ DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm comment_letter033011.htm

 
 
 
 
 
April 7, 2011

Mr. Donald E. Field
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Mail Stop 5
Washington, D.C. 20549-3561
 
Re:          Ruby Tuesday, Inc.
                Form 10-K for the Fiscal Year Ended June 1, 2010
                Filed August 2, 2010
                File No. 001-12454
 
Dear Mr. Field:

Ruby Tuesday, Inc. (the “Company” or “we”) received the Staff’s comment letter dated March 30, 2011 with respect to the above-referenced filing.  Our response to the Staff’s comment is set forth below.  For ease of reference, our response sets forth below the full text of the correlative Staff comment.

Form 10-K for the Fiscal Year Ended June 1, 2010


Exhibits 31.1 and 31.2

1.           We note that in paragraph 4(d) of the certifications required by Exchange Act Rule 13a-14(a) that in each certification the language “(the registrant’s fourth fiscal quarter in the case of an annual report)” has been deleted.  In future filings, the certifications should be revised to track the language exactly as set forth in Item 601(b)(31) of Regulation S-K.

 
We confirm that, in future filings, we will ensure that our certification language will track exactly the language as set forth in Item 601(b)(31) of Regulation S-K.

We acknowledge that we are responsible for the accuracy and the adequacy of the disclosure in the filing.

We acknowledge that Staff comments or changes to disclosure in response to Staff comments do not foreclose the Securities and Exchange Commission (“SEC”) from taking any action with respect to the filing.

We acknowledge that we may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.







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Securities and Exchange Commission
April 7, 2011
Page 2
 
 
 
Please do not hesitate to contact me at (865) 379-5700 with any questions or comments.

Sincerely,

­­­­/s/ Marguerite N. Duffy                                           
Marguerite N. Duffy
Senior Vice President, Chief Financial Officer
and Principal Accounting Officer

cc:           Scarlett May, Vice President, General Counsel and Secretary