SEC Comment Letter for Allegiant Travel CO (ALGT) (CIK 0001362468) (ALGT) — Aug 8, 2017
Allegiant Travel CO (ALGT) (CIK 0001362468)
Date: Aug. 8, 2017 · CIK: 0001362468 · Accession: 0000000000-17-028048
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33166
Letter
Mail Stop 3561 August 8, 2017 Scott Sheldon Chief Financial Officer Allegiant Travel Company 1201 N. Town Center Drive Las Vegas, NV 80144
Re: Allegiant Travel Company Form 10-K for the fiscal year ended December 31, 2016 Filed February 24, 2017 File No. 001-33166
Dear Mr. Sheldon :
We have limited our review of your filing to the financial statements and related disclosures and 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.
Form 10 -K for the fiscal year ended December 3 1, 2016
Trends, page 29
1. Please quantify the total expected impact of the retirement of the MD -80 aircraft on the related accelerated depreciation expense .
Item 7: Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 30
2. We note that depreciation in future periods will outpace prior periods due to several factors including the retirement of the MD -80 aircraft, the addition of new aircraft into service, as well as major maintenance of your Air bus aircraft under the deferral method of accounting. Please revise your discussion of changes in depreciation between periods to quantify each of the above factors’ contribution to the overall change in the amount.
Scott Sheldon Allegiant Travel Company August 8, 2017 Page 2
We remind you that the company and it s management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 if you have questions regarding comments on the financial statements and rel ated matters. Please contact me at 202-551-3380 with any other questions.
Sincerely,
/s/ Melissa Raminpour for
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Mail Stop 3561 August 8, 2017 Scott Sheldon Chief Financial Officer Allegiant Travel Company 1201 N. Town Center Drive Las Vegas, NV 80144 Re: Allegiant Travel Company Form 10-K for the fiscal year ended December 31, 2016 Filed February 24, 2017 File No. 001-33166 Dear Mr. Sheldon : We have limited our review of your filing to the financial statements and related disclosures and 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. Form 10 -K for the fiscal year ended December 3 1, 2016 Trends, page 29 1. Please quantify the total expected impact of the retirement of the MD -80 aircraft on the related accelerated depreciation expense . Item 7: Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 30 2. We note that depreciation in future periods will outpace prior periods due to several factors including the retirement of the MD -80 aircraft, the addition of new aircraft into service, as well as major maintenance of your Air bus aircraft under the deferral method of accounting. Please revise your discussion of changes in depreciation between periods to quantify each of the above factors’ contribution to the overall change in the amount. Scott Sheldon Allegiant Travel Company August 8, 2017 Page 2 We remind you that the company and it s management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Amy Geddes at 202-551-3304 or Theresa Brillant at 202-551-3307 if you have questions regarding comments on the financial statements and rel ated matters. Please contact me at 202-551-3380 with any other questions. Sincerely, /s/ Melissa Raminpour for Lyn Shenk Branch Chief Office of Transportation and Leisure