TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo May 11, 2023 Nanci Prado Deputy General Counsel LEVI STRAUSS & CO. 1155 Battery Street San Francisco, CA 94111 Re: LEVI STRAUSS & CO. Form 10-K for the Fiscal Year Ended November 27, 2022 Response Dated May 2, 2023 File No. 001-06631 Dear Nanci Prado: We have reviewed your May 2, 2023 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 April 18, 2023 letter. Response Letter Dated May 2, 2023 Appendix A, page 5 1. We note that on the last page of Appendix A, you disclose Adjusted Diluted Earnings Per Share at the bottom of your reconciliation of net income to Adjusted Net Income. Please revise to present a reconciliation of diluted EPS to Adjusted Diluted EPS. Additionally, wherever you present a Non GAAP margin measure in Appendix A, please revise to disclose the most comparable margin presented in accordance with GAAP. Nanci Prado FirstName LastNameNanci LEVI STRAUSS & CO. Prado Comapany May NameLEVI STRAUSS & CO. 11, 2023 May 11, Page 2 2023 Page 2 FirstName LastName You may contact Stephany Yang at (202) 551-3167 or Claire Erlanger at (202) 551- 3301 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing