SEC Comment Letter 0000000000-23-014040 to KBR, INC. (KBR) (CIK 0001357615) (KBR)
KBR, INC. (KBR) (CIK 0001357615)
Date: Dec. 22, 2023 · CIK: 0001357615 · Accession: 0000000000-23-014040
AI Filing Summary & Sentiment
File numbers found in text: 001-33146
Letter
United States securities and exchange commission logo December 22, 2023 Mark W. Sopp Executive Vice President and Chief Financial Officer KBR, Inc. 601 Jefferson Street, Suite 3400 Houston, TX 77002 Re:KBR, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Form 8-K filed November 2, 2023 File No. 001-33146 Dear Mark W. Sopp: 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.
FirstName LastNameMark W. Sopp Comapany NameKBR, Inc. December 22, 2023 Page 2 FirstName LastName Mark W. Sopp KBR, Inc. December 22, 2023 Page 2 Form 8-K filed November 2, 2023 Exhibit 99.1 EBITDA and Adjusted EBITDA, page 11 1.We note you have included an adjustment for charges associated with Convertible Notes in your calculation of EBITDA. To the extent you are making adjustments to Net income (loss) for anything other than interest, taxes, depreciation or amortization, the Non-GAAP measure should not be characterized as EBITDA, and its title should be distinguished from EBITDA. Refer to Question 103.01 of the Non-GAAP Financial Measures C&DI. 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. Please contact Eric McPhee at 202-551-3693 or Mark Rakip at 202-551-3573 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
December 22, 2023
Mark W. Sopp
Executive Vice President and Chief Financial Officer
KBR, Inc.
601 Jefferson Street, Suite 3400
Houston, TX 77002
Re:KBR, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Form 8-K filed November 2, 2023
File No. 001-33146
Dear Mark W. Sopp:
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.
FirstName LastNameMark W. Sopp
Comapany NameKBR, Inc.
December 22, 2023 Page 2
FirstName LastName
Mark W. Sopp
KBR, Inc.
December 22, 2023
Page 2
Form 8-K filed November 2, 2023
Exhibit 99.1
EBITDA and Adjusted EBITDA, page 11
1.We note you have included an adjustment for charges associated with Convertible Notes
in your calculation of EBITDA. To the extent you are making adjustments to Net income
(loss) for anything other than interest, taxes, depreciation or amortization, the Non-GAAP
measure should not be characterized as EBITDA, and its title should be distinguished
from EBITDA. Refer to Question 103.01 of the Non-GAAP Financial Measures C&DI.
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.
Please contact Eric McPhee at 202-551-3693 or Mark Rakip at 202-551-3573 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction