TEXT-EXTRACT 2 filename2.txt October 31, 2018 Scott Kriss Chief Accounting Officer OFFICE DEPOT INC 6600 North Military Trail Boca Raton, Florida 33496 Re: OFFICE DEPOT INC Form 10-K for the Fiscal Year Ended December 31, 2017 Filed February 28, 2018 Form 8-K Filed August 7, 2018 File No. 001-10948 Dear Mr. Kriss: We have limited our review of your filing to the financial statements and related disclosures 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 8-K Filed August 7, 2018 Exhibit 99.1, page 1 1. Reference is made to your disclosure of historical and expected free cash flow. Regarding both historical and expected free cash flow, please tell us your consideration of providing the disclosures prescribed by Item 10(e)(1)(i)(B)-(D) of Regulation S-K. Regarding your presentation of expected free cash flow, please tell us your consideration of disclosing expected operating cash flow with equal or greater prominence. Refer to Item 10(e)(i)(A) of Regulation S-K. Exhibit 99.1, page 4 2. Reference is made to your presentation of CompuCom unaudited adjusted historical Scott Kriss OFFICE DEPOT INC October 31, 2018 Page 2 results for the second quarter of 2017 and for fiscal 2017 . Please tell us how the historical results were adjusted. In addition, tell us your consideration of whether the adjusted historical results represent non-GAAP measures. Refer to Item 10(e)(2) of Regulation S-K. Exhibit 99.1, page 10 3. Reference is made to your reconciliations of GAAP amounts to Non-GAAP amounts. Please tell us your consideration of including footnote disclosure that describes the reconciling items when not obvious given the line item description. In closing, 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. You may contact Adam Phippen, Staff Accountant, at (202) 551-3336 or William Thompson, Accounting Branch Chief, at (202) 551-3344 with any questions. Sincerely, FirstName LastNameScott Kriss Division of Corporation Finance Comapany NameOFFICE DEPOT INC Office of Consumer Products October 31, 2018 Page 2 cc: David Bleisch FirstName LastName