SEC Comment Letter for UNITED RENTALS NORTH AMERICA INC (CIK 0001047166) — May 5, 2020
UNITED RENTALS NORTH AMERICA INC (CIK 0001047166)
Date: May 5, 2020 · CIK: 0001047166 · Accession: 0000000000-20-003930
AI Filing Summary & Sentiment
File numbers found in text: 001-14387
Letter
United States securities and exchange commission logo May 5, 2020 Jessica T. Graziano Chief Financial Officer United Rentals, Inc. 100 First Stamford Place, Suite 700 Stamford, Connecticut 06902 Re:United Rentals, Inc. Form 10-K for the Year Ended December 31, 2019 Filed January 29, 2020 File No. 001-14387 Dear Ms. Graziano: 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-K for the Year Ended December 31, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Financial Overview EBITDA GAAP Reconciliations, page 24 1.On page 26 you disclose margins for "EBITDA" and "adjusted EBITDA." Please present with equal or greater prominence the comparable margins computed on a GAAP basis wherever these non-GAAP margins are presented. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the staff’s Compliance and Disclosure Interpretations “Non-GAAP Financial Measures.”
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.
FirstName LastNameJessica T. Graziano Comapany NameUnited Rentals, Inc. May 5, 2020 Page 2 FirstName LastName Jessica T. Graziano United Rentals, Inc. May 5, 2020 Page 2 You may contact Aamira Chaudhry at 202-551-3389 or Doug Jones at 202-551-3309 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
May 5, 2020
Jessica T. Graziano
Chief Financial Officer
United Rentals, Inc.
100 First Stamford Place, Suite 700
Stamford, Connecticut 06902
Re:United Rentals, Inc.
Form 10-K for the Year Ended December 31, 2019
Filed January 29, 2020
File No. 001-14387
Dear Ms. Graziano:
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-K for the Year Ended December 31, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Financial Overview
EBITDA GAAP Reconciliations, page 24
1.On page 26 you disclose margins for "EBITDA" and "adjusted EBITDA." Please present
with equal or greater prominence the comparable margins computed on a GAAP basis
wherever these non-GAAP margins are presented. Refer to Item 10(e)(1)(i)(A) of
Regulation S-K and Question 102.10 of the staff’s Compliance and Disclosure
Interpretations “Non-GAAP Financial Measures.”
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.
FirstName LastNameJessica T. Graziano
Comapany NameUnited Rentals, Inc.
May 5, 2020 Page 2
FirstName LastName
Jessica T. Graziano
United Rentals, Inc.
May 5, 2020
Page 2
You may contact Aamira Chaudhry at 202-551-3389 or Doug Jones at 202-551-3309
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services