Correspondence 0001104659-24-102449 from RB GLOBAL INC. (RBA)
RB GLOBAL INC.
Date: Sept. 24, 2024 · CIK: 0001046102 · Accession: 0001104659-24-102449
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13425
Referenced dates: September 20, 2024
Letter
VIA EDGAR SUBMISSION Division of Corporation Finance Office of Life Sciences United States Securities and Exchange Commission Re: RB Global, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Filed February 28, 2024 File No. 001-13425
Dear Ms. Rucha Pandit & Ms. Suzanne Hayes:
This letter is written in response to the comments included in your letter dated September 20, 2024, regarding your review of RB Global, Inc.’s Forms 10-K referenced above. We have included your original comments in bold text below for your convenience. References in this letter to “we,” “our,” “us” or “the Company” are to RB Global, Inc. and its subsidiaries.
“Item 1C. Cybersecurity Governance, page 33
1. We note your disclosure that your cybersecurity risk management and strategy processes are overseen by leaders from your Information Security, Information Technology, Product Management, Risk Management and Legal teams, including your CISO and CPTO. Please confirm that in future filings you will disclose the relevant expertise of each person and each team member responsible for assessing and managing material risks from cybersecurity threats in such detail as necessary to fully describe the nature of the expertise, including the amount of time served in relevant roles. Discussing the individuals’ experiences in the aggregate is not sufficient. Please see Item 106(c)(2)(i) of Regulation S-K.”
For future filings, we will disclose the relevant expertise of each person and each team member responsible for assessing and managing material risks from cybersecurity threats in such detail as necessary to fully describe the nature of the expertise, including the amount of time served in relevant roles, as set forth in Item 106(c)(2)(i) of Regulation S-K.
Sincerely,
RB Global, Inc.
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Two Westbrook Corporate Center
Suite #1000
Westchester, IL 60154
USA Toll-Free: +1.800.663.8457
Canada Toll-Free: +1.800.663.1739
September 24, 2024
VIA EDGAR SUBMISSION
Rucha Pandit & Suzanne Hayes
Division of Corporation Finance
Office of Life Sciences
United States Securities and Exchange Commission
Washington, D.C 20549
Re: RB Global, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed February 28, 2024
File No. 001-13425
Dear Ms. Rucha Pandit & Ms. Suzanne Hayes:
This letter is written in response to the comments included in your
letter dated September 20, 2024, regarding your review of RB Global, Inc.’s Forms 10-K referenced above. We have included your original
comments in bold text below for your convenience. References in this letter to “we,” “our,” “us” or
“the Company” are to RB Global, Inc. and its subsidiaries.
“Item 1C. Cybersecurity Governance, page 33
1. We
note your disclosure that your cybersecurity risk management and strategy processes are overseen
by leaders from your Information Security, Information Technology, Product Management, Risk
Management and Legal teams, including your CISO and CPTO. Please confirm that in future filings
you will disclose the relevant expertise of each person and each team member responsible
for assessing and managing material risks from cybersecurity threats in such detail as necessary
to fully describe the nature of the expertise, including the amount of time served in relevant
roles. Discussing the individuals’ experiences in the aggregate is not sufficient.
Please see Item 106(c)(2)(i) of Regulation S-K.”
For future filings, we will disclose
the relevant expertise of each person and each team member responsible for assessing and managing material risks from cybersecurity threats
in such detail as necessary to fully describe the nature of the expertise, including the amount of time served in relevant roles, as set
forth in Item 106(c)(2)(i) of Regulation S-K.
Sincerely,
RB Global, Inc.
/s/ Darren Watt
September 24, 2024
Darren Watt
Date
Chief Legal Officer
rbglobal.com Page 1