SEC Comment Letter for Sunstone Hotel Investors, Inc. (SHO, SHO-PH, SHO-PI) (CIK 0001295810) (SHO) — Dec 13, 2010
Sunstone Hotel Investors, Inc. (SHO, SHO-PH, SHO-PI) (CIK 0001295810)
Date: Dec. 13, 2010 · CIK: 0001295810 · Accession: 0000000000-10-074361
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-32319
Referenced dates: December 10, 2010
Letter
December 13, 2010 Mr. Kenneth E. Cruse Chief Financial Officer Sunstone Hotel Investors, Inc. 120 Vantis, Suite 350 Aliso Viejo, California 92656 Re: Sunstone Hotel Investors, Inc. Form 10-K for the year ended December 31, 2009 Filed on February 23, 2010 File No. 001-32319
Dear Mr. Kenneth E. Cruse: We have reviewed your response letter dated December 10, 2010 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 letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2009
Item 7 – Management’s Discussion and Analys is of Financial Condition and Results of Operations, page 28 Non-GAAP Financial Measures, page 35
1. We have considered your response to comment one. Please clarify how adjusting for loan penalties and fees to arrive at EBITDA meets the criteria outlined within the Exchange Act Release No. 47226.
Kenneth E. Cruse Sunstone Hotel Investors, Inc. December 13, 2010 Page 2
You may contact Wilson K. Lee, at (202) 551-3468 or me, at (202) 551-3472 if you have any questions. Sincerely,
Yolanda Crittendon Staff Accountant
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December 13, 2010 Mr. Kenneth E. Cruse Chief Financial Officer Sunstone Hotel Investors, Inc. 120 Vantis, Suite 350 Aliso Viejo, California 92656 Re: Sunstone Hotel Investors, Inc. Form 10-K for the year ended December 31, 2009 Filed on February 23, 2010 File No. 001-32319 Dear Mr. Kenneth E. Cruse: We have reviewed your response letter dated December 10, 2010 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 letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2009 Item 7 – Management’s Discussion and Analys is of Financial Condition and Results of Operations, page 28 Non-GAAP Financial Measures, page 35 1. We have considered your response to comment one. Please clarify how adjusting for loan penalties and fees to arrive at EBITDA meets the criteria outlined within the Exchange Act Release No. 47226. Kenneth E. Cruse Sunstone Hotel Investors, Inc. December 13, 2010 Page 2 You may contact Wilson K. Lee, at (202) 551-3468 or me, at (202) 551-3472 if you have any questions. Sincerely, Yolanda Crittendon Staff Accountant