DULUTH HOLDINGS INC. (DLTH)

Company response: We respectfully acknowledge the Staff’s comment and we advise that in future annual reports to security holders, we will include a table that reconciles any non-GAAP financial measure to its most directly comparable GAAP measure, including any reconciliations required in our Annual Report to Security Holders for Fiscal Year Ended February 1, 2026. By way of example, the following is a reconciliation of Adjusted Diluted EPS that was included in our earnings release furnished as part of the Current Report on Form 8-K, dated March 11, 2025. DULUTH HOLDINGS INC. Reconciliation of Net Loss to Adjusted Net Loss and Adjusted Net Loss to Adjusted EPS (Unaudited) Three Months Ended Twelve Months… response letter →

Company response: The “tax valuation allowance” adjustment represents a discrete, non-cash charge recorded to establish a valuation allowance against deferred tax assets. We record net deferred tax assets to the extent we believe these assets will more likely than not be realized. A valuation allowance is established if it is more likely than not that some portion or all of the deferred income tax asset will not be realized. The Company considers this a discrete adjustment rather than a reflection of the Company’s ongoing performance. It also does not preclude our business from utilizing the underlying tax credits for which the valuation allowance was established. Management believes excluding this discrete… response letter →