SEC Comment Letter for VAIL RESORTS INC (MTN) (CIK 0000812011) (MTN) — Apr 7, 2026
VAIL RESORTS INC (MTN) (CIK 0000812011)
Date: April 7, 2026 · CIK: 0000812011 · Accession: 0000000000-26-003466
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-09614
Letter
Re: Vail Resorts, Inc. Form 10-K for Fiscal Year Ended July 31, 2025 File No. 001-09614 Dear Angela A. Korch:
April 7, 2026
Angela A. Korch Executive Vice President and Chief Financial Officer Vail Resorts, Inc. 390 Interlocken Crescent Broomfield, Colorado 80021
We have limited our review of your filing to the financial statements and related disclosures and have the following comment.
Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended July 31, 2025 Management's Discussion and Analysis of Financial Condition and Results of Operations Reconciliation of Non-GAAP Measures, page 53
1. Your calculation of Total Reported EBITDA excludes items other than interest, taxes, depreciation and amortization. Similarly, your calculation of free cash flow on page 107 of your March 2026 Investors' Conference presentation differs from free cash flow as typically calculated. Please consider revising the titles of these measures to make clear they are further adjusted. See guidance in Non-GAAP CFI (formerly C&DI) 103.01 and 100.05. 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. April 7, 2026 Page 2
Please contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any questions.
Sincerely,
Division of Corporation
Finance
Office of Trade &
Services
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> April 7, 2026 Angela A. Korch Executive Vice President and Chief Financial Officer Vail Resorts, Inc. 390 Interlocken Crescent Broomfield, Colorado 80021 Re: Vail Resorts, Inc. Form 10-K for Fiscal Year Ended July 31, 2025 File No. 001-09614 Dear Angela A. Korch: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for Fiscal Year Ended July 31, 2025 Management's Discussion and Analysis of Financial Condition and Results of Operations Reconciliation of Non-GAAP Measures, page 53 1. Your calculation of Total Reported EBITDA excludes items other than interest, taxes, depreciation and amortization. Similarly, your calculation of free cash flow on page 107 of your March 2026 Investors' Conference presentation differs from free cash flow as typically calculated. Please consider revising the titles of these measures to make clear they are further adjusted. See guidance in Non-GAAP CFI (formerly C&DI) 103.01 and 100.05. 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. April 7, 2026 Page 2 Please contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services </TEXT> </DOCUMENT>