SEC Comment Letter 0000000000-23-003820 to MARRIOTT INTERNATIONAL INC /MD/ (MAR) (CIK 0001048286) (MAR)
MARRIOTT INTERNATIONAL INC /MD/ (MAR) (CIK 0001048286)
Date: April 17, 2023 · CIK: 0001048286 · Accession: 0000000000-23-003820
AI Filing Summary & Sentiment
File numbers found in text: 001-13881
Letter
United States securities and exchange commission logo April 17, 2023 Kathleen K. Oberg Chief Financial Officer Marriott International, Inc. 7750 Wisconsin Avenue Bethesda, Maryland 20814 Re:Marriott International, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Form 8-K Filed February 14, 2023 File Nos. 001-13881 Dear Kathleen K. Oberg: We have limited our review of your filings to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments.
FirstName LastNameKathleen K. Oberg Comapany NameMarriott International, Inc. April 17, 2023 Page 2 FirstName LastName Kathleen K. Oberg Marriott International, Inc. April 17, 2023 Page 2 Form 8-K filed Feburary 14, 2023 Exhibit 99 Company Outlook, page 5 1.We note you provide ranges for Adjusted EPS - diluted for your first quarter 2023 and full-year fiscal 2023 guidance. However, you did not provide reconciliations to the most directly comparable GAAP measures. In future filings, please provide the reconciliations required by Item 10(e)(1)(i) of Regulation S-K. To the extent you are relying on the “unreasonable efforts” exception in Item 10(e)(1)(i)(B), revise future filings to disclose this fact and identify any information that is unavailable and its probable significance. Reference is made to Question 102.10 of the Division’s Compliance and Disclosure Interpretations for 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. You may contact Isaac Esquivel at 202-551-3395 or Mark Rakip at 202-551-3573 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Stephanie Carrick
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United States securities and exchange commission logo
April 17, 2023
Kathleen K. Oberg
Chief Financial Officer
Marriott International, Inc.
7750 Wisconsin Avenue
Bethesda, Maryland 20814
Re:Marriott International, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Form 8-K
Filed February 14, 2023
File Nos. 001-13881
Dear Kathleen K. Oberg:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
FirstName LastNameKathleen K. Oberg
Comapany NameMarriott International, Inc.
April 17, 2023 Page 2
FirstName LastName
Kathleen K. Oberg
Marriott International, Inc.
April 17, 2023
Page 2
Form 8-K filed Feburary 14, 2023
Exhibit 99
Company Outlook, page 5
1.We note you provide ranges for Adjusted EPS - diluted for your first quarter 2023 and
full-year fiscal 2023 guidance. However, you did not provide reconciliations to the most
directly comparable GAAP measures. In future filings, please provide the
reconciliations required by Item 10(e)(1)(i) of Regulation S-K. To the extent you are
relying on the “unreasonable efforts” exception in Item 10(e)(1)(i)(B), revise future filings
to disclose this fact and identify any information that is unavailable and its
probable significance. Reference is made to Question 102.10 of the Division’s
Compliance and Disclosure Interpretations for 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.
You may contact Isaac Esquivel at 202-551-3395 or Mark Rakip at 202-551-3573 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Stephanie Carrick