Statement of Cash Flows (ASC 230)

Company response: We respectfully acknowledge the Staff’s comments and will expand our disclosures to include a comparative analysis and discussion of changes in cash flows from operating activities in future filings. The following is an example of the future disclosure: Cash Flows from Operating Activities Our cash flow provided by operations is primarily from net sales and membership fees. Cash flow used in operations generally consists of payments to merchandise suppliers, warehouse operating costs, including wages and employee benefits, utilities, credit and debit card processing fees, and operating leases. Cash used in operations also includes payments for income taxes. Changes in our net investment in… response letter →

Company response: The Company advises the Staff on a supplemental basis that the Company is an internally managed business development company and, as part of management operations, incur fix asset costs. Specifically, during the year ended March 31, 2025, the realized loss on disposal of fixed assets related to the Company’s disposition of certain office equipment, and the acquisition of fixed assets related to the Company’s purchase of office furniture for its office. The realized loss on disposal of fixed assets is included in operating activities as a reconciliation of net income and net cash flow from operating activities in accordance with ASC 230-10-45-28(b). Cash outflows for the acquisition of fixed… response letter →

Company response: We acknowledge the Staff’s comment and will revise future disclosures to comply with Item 10(e)(1)(i)(A) of Regulation S-K by presenting or discussing the most directly comparable GAAP measure with equal or greater prominence. Exhibit 99.1, page 7 4. Reference is made to page 7. Please tell us the Adjusted net income (loss) effective tax rate for each period presented and explain why it’s reasonable. In this regard, tell us your consideration of including current and deferred income tax expense commensurate with this non-GAAP measure of profitability. Refer to Question 102.11 of the Staff’s Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Response: We acknowledge… response letter →

Company response: Refer to ASC 230-10-45-21D. Response: The Company respectfully acknowledges the Staff’s comment. The Company has elected and will disclose in its upcoming Form 10-K for the year ending February 28, 2026 and future filings, to follow the cumulative earnings approach when determining the classification of distributions received from equity method investees, in accordance with ASC 230-10-45-21D. In future filings, beginning with the Company’s Form 10-K for the year ending February 28, 2026, we will update our accounting policy to include information substantially similar to the following: Investment in Unconsolidated Joint Venture We account for the investment in our joint venture under the… response letter →

Company response: The Company acknowledges the Staff’s comment, and in future filings, beginning with our Form 10-Q for the quarter ended September 30, 2025, we will expand disclosures to provide additional quantitative information related to material factors contributing to period-over-period changes in our operating cash flows. In future filings, we intend to expand our disclosures to be similar to the example provided in the below revised disclosure excerpts from our Form 10-K for the year ended December 31, 2024, within the Analysis of Cash Flow section of Management’s Discussion and Analysis of Financial Condition and Results of Operations. Our revisions are marked in bold. Form 10-K for year-ended… response letter →