SEC Company Response from Strategic Education, Inc. (STRA) (CIK 0001013934) (STRA) — Dec 20, 2019
Strategic Education, Inc. (STRA) (CIK 0001013934)
Date: Dec. 20, 2019 · CIK: 0001013934 · Accession: 0001104659-19-074964
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-21039
Referenced dates: December 12, 2019
Letter
Division of Corporation Finance 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
RE: Strategic Education, Inc.
Dear Ms. Li and Mr. Decker:
Strategic Education, Inc. (“SEI” or the “Company”) respectfully submits below SEI’s responses to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission contained in your letter dated December 12, 2019. For your convenience, we have set forth below the Staff’s comments in italics, followed by SEI’s responses thereto.
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.
We acknowledge the Staff’s comment and undertake that in future filings we will separately disclose accounts payable and accrued expenses, as well as significant components of accrued expenses as required.
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 acknowledge the Staff’s comment and undertake that in future filings with the Securities and Exchange Commission and earnings releases we will reconcile our non-GAAP measures to the most directly comparable GAAP measures without presenting a full non-GAAP income statement.
* * *
Should any member of the Staff have any questions or comments concerning this letter, please do not hesitate to call me at 703-713-1862. Thank you.
Very truly yours,
/s/ Daniel W. Jackson
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CORRESP 1 filename1.htm December 20, 2019 Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: Ms. Suying Li Mr. Rufus Decker 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 Ms. Li and Mr. Decker: Strategic Education, Inc. (“SEI” or the “Company”) respectfully submits below SEI’s responses to the comments of the Staff (the “Staff”) of the Securities and Exchange Commission contained in your letter dated December 12, 2019. For your convenience, we have set forth below the Staff’s comments in italics, followed by SEI’s responses thereto. 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. We acknowledge the Staff’s comment and undertake that in future filings we will separately disclose accounts payable and accrued expenses, as well as significant components of accrued expenses as required. 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 acknowledge the Staff’s comment and undertake that in future filings with the Securities and Exchange Commission and earnings releases we will reconcile our non-GAAP measures to the most directly comparable GAAP measures without presenting a full non-GAAP income statement. * * * Should any member of the Staff have any questions or comments concerning this letter, please do not hesitate to call me at 703-713-1862. Thank you. Very truly yours, /s/ Daniel W. Jackson Daniel W. Jackson Executive Vice President and Chief Financial Officer