SEC Comment Letter 0000000000-23-011270 to LAUREATE EDUCATION, INC. (LAUR) (CIK 0000912766) (LAUR)
LAUREATE EDUCATION, INC. (LAUR) (CIK 0000912766)
Date: Oct. 16, 2023 · CIK: 0000912766 · Accession: 0000000000-23-011270
AI Filing Summary & Sentiment
File numbers found in text: 001-38002
Letter
United States securities and exchange commission logo October 16, 2023 Richard Buskirk Senior Vice President and Chief Financial Officer Laureate Education, Inc. PMB 1158 1000 Bricknell Avenue, Suite 715 Miami, FL 33131 Re:Laureate Education, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 23, 2023 File No. 001-38002 Dear Richard Buskirk: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand yourdisclosure. 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 our 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 December 31, 2022 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measure, page 39 1.We note that your calculation for EBITDA begins with income (loss) from continuing operations rather than net income (loss). Please explain why you believe this presentation is appropriate or revise. Refer to Question 103.02 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. 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.
FirstName LastNameRichard Buskirk Comapany NameLaureate Education, Inc. October 16, 2023 Page 2 FirstName LastName Richard Buskirk Laureate Education, Inc. October 16, 2023 Page 2 Please contact Blaise Rhodes at 202-551-3774 or Angela Lumley at 202-551-3398, if you have any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
October 16, 2023
Richard Buskirk
Senior Vice President and Chief Financial Officer
Laureate Education, Inc.
PMB 1158
1000 Bricknell Avenue, Suite 715
Miami, FL 33131
Re:Laureate Education, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 23, 2023
File No. 001-38002
Dear Richard Buskirk:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand yourdisclosure.
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 our
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 December 31, 2022
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Measure, page 39
1.We note that your calculation for EBITDA begins with income (loss) from continuing
operations rather than net income (loss). Please explain why you believe this presentation
is appropriate or revise. Refer to Question 103.02 of the Non-GAAP Financial Measures
Compliance and Disclosure Interpretations.
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.
FirstName LastNameRichard Buskirk
Comapany NameLaureate Education, Inc.
October 16, 2023 Page 2
FirstName LastName
Richard Buskirk
Laureate Education, Inc.
October 16, 2023
Page 2
Please contact Blaise Rhodes at 202-551-3774 or Angela Lumley at 202-551-3398, if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services