TEXT-EXTRACT 2 filename2.txt October 30, 2019 Brian P. Lynch Chief Financial Officer Callaway Golf Company 2180 Rutherford Road Carlsbad, California 92008 Re: Callaway Golf Company Form 10-K for the Fiscal Year Ended December 31, 2018 Form 10-Q for the Quarterly Period Ended June 30, 2019 Form 8-K Filed on August 8, 2019 Response letter dated October 18, 2019 File No. 001-10962 Dear Mr. Lynch: We have reviewed your October 18, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our September 20, 2019 letter. Response Letter Dated October 18, 2019 Form 10-Q for the Quarter Ended June 30, 2019 Note 18. Segments, page 34 1. We note from your response to our prior comment 2 that you have structured your management teams to oversee the design, sales, marketing and operations of the golf club and golf ball operations as one single Golf Equipment business with a separate management team to oversee the soft goods business. Please tell us if there is any discrete financial information available for the golf ball product line and the golf clubs product line. If so, please tell us the nature of the information and if the CODM receives this information for use in making resource allocation decisions and assessing performance. Brian P. Lynch Callaway Golf Company October 30, 2019 Page 2 Form 8-K furnished August 8, 2019 Exhibit 99.1 Earnings Release, page 1 2. We note from your response in Exhibit A that you intend to include a table which reconciles the non GAAP forecasted amounts to their comparable GAAP measure. We also note that you include Adjusted EBITDA in the table. Please confirm that you will reconcile the Adjusted EBITDA guidance to net income, its most comparable GAAP measure. If you are unable to provide this reconciliation without unreasonable efforts, please revise to disclose that fact. See Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10 of the SEC Staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures, updated April 4, 2018. You may contact Beverly Singleton at (202) 551-3328 or Claire Erlanger at (202) 551- 3301 if you have questions regarding comments on the financial statements and related matters. Please contact Melissa Raminpour at (202) 551-3379 with any other questions. FirstName LastNameBrian P. Lynch Sincerely, Comapany NameCallaway Golf Company Division of Corporation Finance October 30, 2019 Page 2 Office of Manufacturing FirstName LastName