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United States securities and exchange commission logo
October 24, 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
Response dated
October 12, 2023
File No. 001-14170
Dear George R. Bracken:
We have reviewed your October 12, 2023 response to our comment
letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our September 15,
2023 letter.
10-K for Fiscal Year Ended April 29, 2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
12
1. We note your response
to prior comment 1 and reissue it in part. Please explain how you
evaluate
climate-related regulations and business trends, and describe your analytical
procedure in
determining that you have not observed, in any quantifiable manner, each of
the indirect
consequences of climate-related regulations or business trends for which
disclosure was not
deemed necessary. In addition, describe your analyses in concluding
that to date you had
not experienced a material impact on your operations due to being
perceived as
inattentive to the risks of climate change and/or unresponsive to increasing
demands for information
and action by various stakeholders. Please also describe your
analyses for your
determination that you have not identified any material increase or
decrease in demand for
your products due to the potential adverse consequences to your
George R. Bracken
National Beverage Corp.
October 24, 2023
Page 2
reputation resulting from your operations or products that produce
material greenhouse
gas emissions, and provide support for your determinations of
materiality.
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
October 24, 2023 Page 2 Office of Energy &
Transportation
FirstName LastName