SEC Comment Letter for Strategic Education, Inc. (STRA) (CIK 0001013934) (STRA) — Dec 12, 2019
Strategic Education, Inc. (STRA) (CIK 0001013934)
Date: Dec. 12, 2019 · CIK: 0001013934 · Accession: 0000000000-19-016326
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-21039
Letter
December 12, 2019 Daniel Jackson Chief Financial Officer Strategic Education, Inc. 2303 Dulles Station Boulevard Herndon, VA 20171 Re:Strategic Education, Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed March 1, 2019 Form 8-K Filed November 7, 2019 File No. 000-21039 Dear Mr. Jackson: We have reviewed your filings 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. Form 10-K for the Fiscal Year Ended December 31, 2018 Consolidated Financial Statements Consolidated Balance Sheets, page 77 1.Please separately disclose accounts payable and accrued expenses. Also, disclose the significant components of accrued expenses, as required. Refer to Rules 5-02.19 and .20 of Regulation S-X.
FirstName LastNameDaniel Jackson Comapany NameStrategic Education, Inc. December 12, 2019 Page 2 FirstName LastName Daniel Jackson Strategic Education, Inc. December 12, 2019 Page 2 Form 8-K Filed November 7, 2019 Exhibit 99.1 Non-GAAP Financial Measures Unaudited Reconciliation of Non-GAAP Financial Measures Adjusted Income From Operations, Adjusted Net Income, and Adjusted EPS, page 9 2.In reconciling non-GAAP amounts to GAAP amounts, you present a full non-GAAP income statement. Please tell us how you considered the guidance in Question 102.10 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. Please contact Suying Li at (202) 551-3335 or Rufus Decker at (202) 551-3769 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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December 12, 2019
Daniel Jackson
Chief Financial Officer
Strategic Education, Inc.
2303 Dulles Station Boulevard
Herndon, VA 20171
Re:Strategic Education, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed March 1, 2019
Form 8-K Filed November 7, 2019
File No. 000-21039
Dear Mr. Jackson:
We have reviewed your filings 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.
Form 10-K for the Fiscal Year Ended December 31, 2018
Consolidated Financial Statements
Consolidated Balance Sheets, page 77
1.Please separately disclose accounts payable and accrued expenses. Also, disclose
the significant components of accrued expenses, as required. Refer to Rules 5-02.19 and
.20 of Regulation S-X.
FirstName LastNameDaniel Jackson
Comapany NameStrategic Education, Inc.
December 12, 2019 Page 2
FirstName LastName
Daniel Jackson
Strategic Education, Inc.
December 12, 2019
Page 2
Form 8-K Filed November 7, 2019
Exhibit 99.1
Non-GAAP Financial Measures
Unaudited Reconciliation of Non-GAAP Financial Measures
Adjusted Income From Operations, Adjusted Net Income, and Adjusted EPS, page 9
2.In reconciling non-GAAP amounts to GAAP amounts, you present a full non-GAAP
income statement. Please tell us how you considered the guidance in Question 102.10 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.
Please contact Suying Li at (202) 551-3335 or Rufus Decker at (202) 551-3769 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services