SEC Comment Letter for HERBALIFE LTD. (HLF) (CIK 0001180262) (HLF) — May 25, 2018
HERBALIFE LTD. (HLF) (CIK 0001180262)
Date: May 25, 2018 · CIK: 0001180262 · Accession: 0000000000-18-016261
AI Filing Summary & Sentiment
Letter
Mail Stop 3561 May 25, 2018 Via E -mail Mr. Bosco Chiu Chief Financial Officer Herbalife Nutrition Ltd. P.O. Box 309GT Ugland House, South Church St. Grand Cayman, Cayman Islands
Re: Herbalife Nutrition Ltd. Form 10 -K for the Year Ended December 31, 2017 Response dated May 10, 2018 File No. 001 -32381
Dear Mr. Chiu :
We have reviewed your May 10 , 2018 response to our comment letter and hav e 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do no t believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comment s in our May 1, 2018 letter.
Form 10 -K for the Year Ended December 31, 2017
Item 1. Business Member Base, page 8
1. We note your response to comment 1. Please disclose the total membership, including members for China, and your “preferred membe rs” and “distributors” for the fiscal year ended December 31, 2017. Alternatively, please provide a detailed analysis as to how you determined this information is not material.
Bosco Chiu Herbalife Nutrition Ltd . May 25 , 2018 Page 2
You may contact Michael Killoy at (202) 551 -7576 or David Link at (202) 551 -3356 with any questions.
Sincerely,
/s/Craig Arakawa
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Mail Stop 3561 May 25, 2018 Via E -mail Mr. Bosco Chiu Chief Financial Officer Herbalife Nutrition Ltd. P.O. Box 309GT Ugland House, South Church St. Grand Cayman, Cayman Islands Re: Herbalife Nutrition Ltd. Form 10 -K for the Year Ended December 31, 2017 Response dated May 10, 2018 File No. 001 -32381 Dear Mr. Chiu : We have reviewed your May 10 , 2018 response to our comment letter and hav e 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 busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do no t believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment , we may have additional comments. Unless we note otherwise, our references to prior comments are to comment s in our May 1, 2018 letter. Form 10 -K for the Year Ended December 31, 2017 Item 1. Business Member Base, page 8 1. We note your response to comment 1. Please disclose the total membership, including members for China, and your “preferred membe rs” and “distributors” for the fiscal year ended December 31, 2017. Alternatively, please provide a detailed analysis as to how you determined this information is not material. Bosco Chiu Herbalife Nutrition Ltd . May 25 , 2018 Page 2 You may contact Michael Killoy at (202) 551 -7576 or David Link at (202) 551 -3356 with any questions. Sincerely, /s/Craig Arakawa Craig Arakawa Accounting Branch Chief Office of Beverages, Apparel, and Mining