SEC Comment Letter 0000000000-23-007037 to LAS VEGAS SANDS CORP (LVS) (CIK 0001300514) (LVS)
LAS VEGAS SANDS CORP (LVS) (CIK 0001300514)
Date: July 3, 2023 · CIK: 0001300514 · Accession: 0000000000-23-007037
AI Filing Summary & Sentiment
File numbers found in text: 001-32373
Letter
United States securities and exchange commission logo July 3, 2023 Randy Hyzak Executive Vice President and Chief Financial Officer Las Vegas Sands Corp. 5500 Haven Street Las Vegas, NV 89119 Re:Las Vegas Sands Corp. Form 10-K for the year ended December 31, 2022 Filed February 3, 2023 Form 8-K filed January 25, 2023 File No. 001-32373 Dear Randy Hyzak: We have reviewed your April 6, 2023 response to our comment letter 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 our 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 our comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 23, 2023 letter. Form 10-K for the year ending December 31, 2022 Form 8-K filed January 25, 2023 Exhibit 99.1 Non-GAAP Measures, page 6 1.We note your response to comment 2. We believe your adjustments for hold-normalized casino revenue and expense to arrive at consolidated hold-normalized adjusted property EBITDA, hold-normalized adjusted property EBITDA for Macao Operations and Marina Bay Sands, and hold-normalized adjusted net loss from continuing operations attributable to LVS are inconsistent with Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please revise to remove the non-GAAP measures that include adjustments for hold-normalized casino revenue and expense.
FirstName LastNameRandy Hyzak Comapany NameLas Vegas Sands Corp. July 3, 2023 Page 2 FirstName LastName Randy Hyzak Las Vegas Sands Corp. July 3, 2023 Page 2 You may contact Howard Efron at 202-551-3439 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
United States securities and exchange commission logo
July 3, 2023
Randy Hyzak
Executive Vice President and Chief Financial Officer
Las Vegas Sands Corp.
5500 Haven Street
Las Vegas, NV 89119
Re:Las Vegas Sands Corp.
Form 10-K for the year ended December 31, 2022
Filed February 3, 2023
Form 8-K filed January 25, 2023
File No. 001-32373
Dear Randy Hyzak:
We have reviewed your April 6, 2023 response to our comment letter 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 our 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 our comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
March 23, 2023 letter.
Form 10-K for the year ending December 31, 2022
Form 8-K filed January 25, 2023
Exhibit 99.1
Non-GAAP Measures, page 6
1.We note your response to comment 2. We believe your adjustments for hold-normalized
casino revenue and expense to arrive at consolidated hold-normalized adjusted property
EBITDA, hold-normalized adjusted property EBITDA for Macao Operations and Marina
Bay Sands, and hold-normalized adjusted net loss from continuing operations attributable
to LVS are inconsistent with Question 100.04 of the Non-GAAP Financial Measures
Compliance and Disclosure Interpretations. Please revise to remove the non-GAAP
measures that include adjustments for hold-normalized casino revenue and expense.
FirstName LastNameRandy Hyzak
Comapany NameLas Vegas Sands Corp.
July 3, 2023 Page 2
FirstName LastName
Randy Hyzak
Las Vegas Sands Corp.
July 3, 2023
Page 2
You may contact Howard Efron at 202-551-3439 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction