SEC Comment Letter for GOODRICH PETROLEUM CORP (CIK 0000943861) — May 25, 2021
GOODRICH PETROLEUM CORP (CIK 0000943861)
Date: May 25, 2021 · CIK: 0000943861 · Accession: 0000000000-21-006561
AI Filing Summary & Sentiment
File numbers found in text: 001-12719
Letter
United States securities and exchange commission logo May 25, 2021 Walter G. Goodrich Chief Executive Officer Goodrich Petroleum Corporation 801 Louisiana, Suite 700 Houston, Texas 77002 Re:Goodrich Petroleum Corporation Form 10-K for the Fiscal Year Ended December 31, 2020 Form 8-K filed May 6, 2021 File No. 001-12719 Dear Mr. Goodrich: We have reviewed your filings and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment 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 our comment, we may have additional comments. Form 8-K filed May 6, 2021 Exhibit 99.1, page 1 1.Your disclosures under the headings Quarter Highlights and Financial Results frequently disclose non-GAAP measures that either precede or exclude a discussion and analysis of the most directly comparable GAAP measures. Please revise disclosures in the quarterly financial results of your press release to provide a discussion and analysis of the most comparable GAAP measures in a location with equal or greater prominence to each instance that a non-GAAP measure is disclosed. See Item 10(e)(1)(i)(A) of Regulation S- K and Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameWalter G. Goodrich Comapany NameGoodrich Petroleum Corporation May 25, 2021 Page 2 FirstName LastName Walter G. Goodrich Goodrich Petroleum Corporation May 25, 2021 Page 2
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. You may contact Joanna Lam at 202-551-3476 or Brian McAllister at 202-551-3341 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
May 25, 2021
Walter G. Goodrich
Chief Executive Officer
Goodrich Petroleum Corporation
801 Louisiana, Suite 700
Houston, Texas 77002
Re:Goodrich Petroleum Corporation
Form 10-K for the Fiscal Year Ended December 31, 2020
Form 8-K filed May 6, 2021
File No. 001-12719
Dear Mr. Goodrich:
We have reviewed your filings and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to the comment 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 our comment, we may have additional comments.
Form 8-K filed May 6, 2021
Exhibit 99.1, page 1
1.Your disclosures under the headings Quarter Highlights and Financial Results frequently
disclose non-GAAP measures that either precede or exclude a discussion and analysis of
the most directly comparable GAAP measures. Please revise disclosures in the quarterly
financial results of your press release to provide a discussion and analysis of the most
comparable GAAP measures in a location with equal or greater prominence to each
instance that a non-GAAP measure is disclosed. See Item 10(e)(1)(i)(A) of Regulation S-
K and Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
FirstName LastNameWalter G. Goodrich
Comapany NameGoodrich Petroleum Corporation
May 25, 2021 Page 2
FirstName LastName
Walter G. Goodrich
Goodrich Petroleum Corporation
May 25, 2021
Page 2
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.
You may contact Joanna Lam at 202-551-3476 or Brian McAllister at 202-551-3341 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation