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United States securities and exchange commission logo
August 3, 2023
George R. Bracken
Executive Vice President Finance
National Beverage Corp.
8100 SW Tenth Street, Suite 4000
Fort Lauderdale, FL 33324
Re: National Beverage
Corp.
Form 10-K for the
Fiscal Year Ended April 29, 2023
Filed June 28, 2023
File No. 001-14170
Dear George R. Bracken:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended April 29, 2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
12
1. To the extent material,
discuss the indirect consequences of climate-related regulation or
business trends, such
as the following:
decreased demand
for goods or services that produce significant greenhouse gas
emissions or are
related to carbon-based energy sources;
increased demand
for goods that result in lower emissions than competing products;
increased
competition to develop innovative new products that result in lower
emissions;
increased demand
for generation and transmission of energy from alternative energy
sources; and
any anticipated
reputational risks resulting from operations or products that produce
material greenhouse
gas emissions.
George R. Bracken
National Beverage Corp.
August 3, 2023
Page 2
2. If material, discuss the physical effects of climate change on your
operations and results.
This disclosure may include the following:
severity of weather, such as floods, hurricanes, sea levels,
arability of farmland,
extreme fires, and water availability and quality;
quantification of material weather-related damages to your
property or operations;
potential for indirect weather-related impacts that have affected
or may affect your
major customers or suppliers;
decreased agricultural production capacity in areas affected by
drought or other
weather-related changes; and
any weather-related impacts on the cost or availability of
insurance.
Your response should include quantitative information for each of the
periods for which
financial statements are presented in your Form 10-K and explain
whether changes are
expected in future periods.
3. If material, please discuss any purchase or sale of carbon credits or
offsets and the effects
on your business, financial condition, and results of operations. To
the extent applicable,
ensure you provide quantitative information with your response for
each of the periods for
which financial statements are presented in your Form 10-K and for any
future periods.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
FirstName LastNameGeorge R. Bracken Sincerely,
Comapany NameNational Beverage Corp.
Division of
Corporation Finance
August 3, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName