SEC Comment Letter 0000000000-24-012218 to DARLING INGREDIENTS INC. (DAR) (CIK 0000916540) (DAR)
DARLING INGREDIENTS INC. (DAR) (CIK 0000916540)
Date: Nov. 4, 2024 · CIK: 0000916540 · Accession: 0000000000-24-012218
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13323
Referenced dates: November 1, 2024
Letter
November 4, 2024 John Sterling Executive Vice President, General Counsel & Secretary Darling Ingredients Inc. 5601 N MacArthur Blvd. Irving, Texas 75038 Re:Darling Ingredients Inc. Form 10-K for the Fiscal Year Ended December 30, 2023 Form 8-K Furnished July 25, 2024 Response Letter Dated November 1, 2024 File No. 001-13323 Dear John Sterling: We have reviewed your November 1, 2024 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our October 21, 2024 letter.
November 4, 2024 Page 2 Response Letter Dated November 1, 2024 Company Response to Staff Comment 4, page 5 1.We note your response to prior comment 4 where segment adjusted EBITDA and combined adjusted EBITDA are reconciled to segment income (loss), which is operating income adjusted by equity in net income of other unconsolidated subsidiaries, and DGD adjusted EBITDA is reconciled to operating income. Please revise future disclosures to reconcile them to net income (loss). The comment also applies to earnings slide presentations furnished in Forms 8-K. Refer to Question 103.02 of the SEC Staff’s Compliance and Disclosure Interpretations on Non- GAAP Financial Measures. Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at 202-551-3777 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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November 4, 2024
John Sterling
Executive Vice President, General Counsel & Secretary
Darling Ingredients Inc.
5601 N MacArthur Blvd.
Irving, Texas 75038
Re:Darling Ingredients Inc.
Form 10-K for the Fiscal Year Ended December 30, 2023
Form 8-K Furnished July 25, 2024
Response Letter Dated November 1, 2024
File No. 001-13323
Dear John Sterling:
We have reviewed your November 1, 2024 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in our October
21, 2024 letter.
November 4, 2024
Page 2
Response Letter Dated November 1, 2024
Company Response to Staff Comment 4, page 5
1.We note your response to prior comment 4 where segment adjusted EBITDA and
combined adjusted EBITDA are reconciled to segment income (loss), which is
operating income adjusted by equity in net income of other unconsolidated
subsidiaries, and DGD adjusted EBITDA is reconciled to operating income. Please
revise future disclosures to reconcile them to net income (loss). The comment also
applies to earnings slide presentations furnished in Forms 8-K. Refer to Question
103.02 of the SEC Staff’s Compliance and Disclosure Interpretations on Non-
GAAP Financial Measures.
Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at 202-551-3777
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing