SEC Comment Letter 0000000000-23-013188 to UNITED RENTALS, INC. (URI) (CIK 0001067701) (URI)
UNITED RENTALS, INC. (URI) (CIK 0001067701)
Date: Dec. 4, 2023 · CIK: 0001067701 · Accession: 0000000000-23-013188
AI Filing Summary & Sentiment
File numbers found in text: 001-14387
Letter
United States securities and exchange commission logo December 4, 2023 William E. Grace Executive Vice President and Chief Financial Officer United Rentals, Inc. 100 First Stamford Place, Suite 700 Stamford, CT 06902 Re:United Rentals, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Form 8-K Furnished January 25, 2023 File No. 001-14387 Dear William E. Grace: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 8-K Furnished January 25, 2023 Exhibit 99.1 Summary of Fourth Quarter 2022 Financial Results Used Equipment Sales 1.You disclose what appears to be a non-GAAP financial measure, used equipment adjusted gross margin. Please revise to reconcile this measure to the most directly comparable GAAP measure, either in a table or by quantifying the adjustment in the related footnote. Refer to Item 10(e)(1)(i)(B) of Regulation S-K. 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 LastNameWilliam E. Grace Comapany NameUnited Rentals, Inc. December 4, 2023 Page 2 FirstName LastName William E. Grace United Rentals, Inc. December 4, 2023 Page 2 Please contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
December 4, 2023
William E. Grace
Executive Vice President and Chief Financial Officer
United Rentals, Inc.
100 First Stamford Place, Suite 700
Stamford, CT 06902
Re:United Rentals, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Form 8-K Furnished January 25, 2023
File No. 001-14387
Dear William E. Grace:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 8-K Furnished January 25, 2023
Exhibit 99.1
Summary of Fourth Quarter 2022 Financial Results
Used Equipment Sales
1.You disclose what appears to be a non-GAAP financial measure, used equipment adjusted
gross margin. Please revise to reconcile this measure to the most directly comparable
GAAP measure, either in a table or by quantifying the adjustment in the related footnote.
Refer to Item 10(e)(1)(i)(B) of Regulation S-K.
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 LastNameWilliam E. Grace
Comapany NameUnited Rentals, Inc.
December 4, 2023 Page 2
FirstName LastName
William E. Grace
United Rentals, Inc.
December 4, 2023
Page 2
Please contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services