SEC Comment Letter for JETBLUE AIRWAYS CORP (JBLU) (CIK 0001158463) (JBLU) — Apr 10, 2017
JETBLUE AIRWAYS CORP (JBLU) (CIK 0001158463)
Date: April 10, 2017 · CIK: 0001158463 · Accession: 0000000000-17-012202
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 April 10 , 2017 Mr. Stephen J. Priest Chief Financial Officer Jetblue Airways Corp 27-01 Queens Plaza North Long Island City, NY 11101
Re: Jetblue Airways Corp Form 10 -K for the Year Ended December 31, 2016 Filed February 1 7, 2017 File No. 00 0-49728
Dear Mr. Priest :
We have reviewed your filing an d 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 busine ss days by providing the requested information or advis e 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.
Return on Invested Capital, page 48
1. We note that in your calculation of ROIC you uti lize an assumption of seven times the amount of aircraft rent. Please clarify the basis for this assumption and tell us whether the multiple of seven compares to contractual terms. If it is significantly different, please clarify why it would be meaningf ul to an investor if it does not depict a realistic picture of your facts and circumstances.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, acti on or absence of action by the staff.
Mr. Stephen J. Priest Jetblue Airways Corp April 10 , 2017 Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, Claire Erlanger, at (202) 551 -3301 if you have questions regarding comments on the financial statements and related matters. Please contact the undersigned, at (202) 551 -3750 with any other questions.
Sincerely,
/s/ Melissa Raminpour
Show Raw Text
Mail Stop 3561
April 10 , 2017
Mr. Stephen J. Priest
Chief Financial Officer
Jetblue Airways Corp
27-01 Queens Plaza North
Long Island City, NY 11101
Re: Jetblue Airways Corp
Form 10 -K for the Year Ended December 31, 2016
Filed February 1 7, 2017
File No. 00 0-49728
Dear Mr. Priest :
We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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.
Return on Invested Capital, page 48
1. We note that in your calculation of ROIC you uti lize an assumption of seven times the
amount of aircraft rent. Please clarify the basis for this assumption and tell us whether
the multiple of seven compares to contractual terms. If it is significantly different, please
clarify why it would be meaningf ul to an investor if it does not depict a realistic picture
of your facts and circumstances.
We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, acti on or absence of
action by the staff.
Mr. Stephen J. Priest
Jetblue Airways Corp
April 10 , 2017
Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, Claire Erlanger, at
(202) 551 -3301 if you have questions regarding comments on the financial statements and
related matters. Please contact the undersigned, at (202) 551 -3750 with any other questions.
Sincerely,
/s/ Melissa Raminpour
Melissa Raminpour
Branch Chief
Office of Transportation and Leisure