0000909832-22-000009.txt : 20220526 0000909832-22-000009.hdr.sgml : 20220526 20220422171222 ACCESSION NUMBER: 0000909832-22-000009 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20220422 FILER: COMPANY DATA: COMPANY CONFORMED NAME: COSTCO WHOLESALE CORP /NEW CENTRAL INDEX KEY: 0000909832 STANDARD INDUSTRIAL CLASSIFICATION: RETAIL-VARIETY STORES [5331] IRS NUMBER: 911223280 STATE OF INCORPORATION: WA FISCAL YEAR END: 0901 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 999 LAKE DRIVE CITY: ISSAQUAH STATE: WA ZIP: 98027- BUSINESS PHONE: 4253138100 MAIL ADDRESS: STREET 1: 999 LAKE DRIVE CITY: ISSAQUAH STATE: WA ZIP: 98027 FORMER COMPANY: FORMER CONFORMED NAME: COSTCO COMPANIES INC DATE OF NAME CHANGE: 19970401 FORMER COMPANY: FORMER CONFORMED NAME: PRICE/COSTCO INC DATE OF NAME CHANGE: 19930728 CORRESP 1 filename1.htm Document

Writer’s Direct Number: (425) 313-8203
Fax: (425) 313-6593

April 22, 2022
BY EDGAR

Robert Shapiro and Theresa Brillant
Division of Corporation Finance
Office of Trade & Services
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Re: Costco Wholesale Corporation -- Form 10-K for the Fiscal Year Ended August 29, 2021, filed
October 6, 2021 -- File No. 000-20355
Dear Mr. Shapiro and Ms. Brillant:

In response to your letter of April 18, 2022 (the “Letter”), please see the discussion below, which corresponds to the paragraph in your letter.
Form 10-K for the Fiscal Year Ended August 29, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Net Sales, page 25
We note per page 23 of your Form 10-K that the inflationary impact to net sales and gross margin is influenced in part by your merchandising and pricing strategies in response to cost increases. We note discussion of these strategies in your Q4 2021, Q1 2022 and Q2 2022 Earnings calls. Please explain and discuss these strategies, similar to the discussion in your earnings calls, as deemed appropriate, in future filings. Refer to Item 303(b) or Regulation S-K.

Response:

We will revise our future disclosure to explain and discuss our merchandising and pricing strategies in response to cost increases.

Please contact me if you have any questions or further comments.
Sincerely,
    
COSTCO WHOLESALE CORPORATION

/s/    RICHARD A. GALANTI
Richard A. Galanti
Executive Vice President, Chief Financial Officer and Director