SEC Comment Letter for RB GLOBAL INC. (RBA) (CIK 0001046102) (RBA) — Nov 9, 2018
RB GLOBAL INC. (RBA) (CIK 0001046102)
Date: Nov. 9, 2018 · CIK: 0001046102 · Accession: 0000000000-18-034952
AI Filing Summary & Sentiment
File numbers found in text: 001-13425
Letter
November 8, 2018 Sharon Driscoll Chief Financial Officer Ritchie Bros. Auctioneers Incorporated 9500 Glenlyon Parkway Burnaby, British Columbia, Canada V5J 0C6 Re:Ritchie Bros. Auctioneers Incorporated Form 10-K for the Fiscal Year Ended December 31, 2017 Filed February 26, 2018 Form 10-Q for the Quarterly Period Ended June 30, 2018 Filed August 9, 2018 File No. 001-13425 Dear Ms. Driscoll: We have limited our review of your filing to the financial statements and related disclosures 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-Q for the Quarterly Period Ended June 30, 2018 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Measures, page 56 1.Your agency proceeds measure includes adjustments for cost of inventory sold and cost of ancillary and logistical services expenses. Explain to us why you believe this measure does not substitute individually tailored recognition and measurement methods for those of GAAP. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameSharon Driscoll Comapany NameRitchie Bros. Auctioneers Incorporated November 8, 2018 Page 2 FirstName LastName Sharon Driscoll Ritchie Bros. Auctioneers Incorporated November 8, 2018 Page 2 In closing, 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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Melissa Kindelan, Senior Staff Accountant at 202-551-3564 with any questions. Sincerely, Division of Corporation Finance Office of Information Technologies and Services
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November 8, 2018
Sharon Driscoll
Chief Financial Officer
Ritchie Bros. Auctioneers Incorporated
9500 Glenlyon Parkway
Burnaby, British Columbia, Canada V5J 0C6
Re:Ritchie Bros. Auctioneers Incorporated
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed February 26, 2018
Form 10-Q for the Quarterly Period Ended June 30, 2018
Filed August 9, 2018
File No. 001-13425
Dear Ms. Driscoll:
We have limited our review of your filing to the financial statements and related
disclosures 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-Q for the Quarterly Period Ended June 30, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures, page 56
1.Your agency proceeds measure includes adjustments for cost of inventory sold and cost of
ancillary and logistical services expenses. Explain to us why you believe this measure
does not substitute individually tailored recognition and measurement methods for those
of GAAP. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance
and Disclosure Interpretations.
FirstName LastNameSharon Driscoll
Comapany NameRitchie Bros. Auctioneers Incorporated
November 8, 2018 Page 2
FirstName LastName
Sharon Driscoll
Ritchie Bros. Auctioneers Incorporated
November 8, 2018
Page 2
In closing, 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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Melissa
Kindelan, Senior Staff Accountant at 202-551-3564 with any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services