SEC Comment Letter 0000000000-22-013205 to Allegiant Travel CO (ALGT)
Allegiant Travel CO
Date: Dec. 7, 2022 · CIK: 0001362468 · Accession: 0000000000-22-013205
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33166
Letter
United States securities and exchange commission logo December 7, 2022 Gregory Anderson Chief Financial Officer Allegiant Travel CO 1201 North Town Center Drive Las Vegas, Nevada 89144 Re:Allegiant Travel CO Form 10-K for the Fiscal Year ended December 31, 2021 Filed March 1, 2022 File No. 001-33166 Dear Gregory Anderson: We have reviewed your November 14, 2022 response to our comment letter 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 business days by providing the requested information or advise 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. Unless we note otherwise, our references to prior comments are to comments in our November 7, 2022 letter. From 10-K for the Fiscal Year ended December 31, 2021 Financial Statements Note 7 - Long Term Debt, page F-71 1.We note your response to prior comment one stating that you will "evaluate including additional detail" regarding your long-term debt in future filings, although you also indicate that you view your present disclosures as fully responsive to the disclosure requirements in Rule 5-02.22 of Regulation S-X.
However, we believe that details should be provided for each issue or type of obligation that is presently combined with dissimilar obligations and with greater specificity. Please submit the revisions that you propose to address this concern.
FirstName LastNameGregory Anderson Comapany NameAllegiant Travel CO December 7, 2022 Page 2 FirstName LastName Gregory Anderson Allegiant Travel CO December 7, 2022 Page 2 If you expect to include aggregated content, explain your rationale or view on the type classification and provide us with a schedule of the related obligations, along with descriptions of the corresponding balances and terms. You may contact John Cannarella, Staff Accountant, at (202) 551-3337 if you have questions regarding comments on the financial statements and related matters. Please contact Karl Hiller, Branch Chief, at (202) 551-3686 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
December 7, 2022
Gregory Anderson
Chief Financial Officer
Allegiant Travel CO
1201 North Town Center Drive
Las Vegas, Nevada 89144
Re:Allegiant Travel CO
Form 10-K for the Fiscal Year ended December 31, 2021
Filed March 1, 2022
File No. 001-33166
Dear Gregory Anderson:
We have reviewed your November 14, 2022 response to our comment letter 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 business days by providing the requested
information or advise 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. Unless we note otherwise, our references to prior comments are to comments in our
November 7, 2022 letter.
From 10-K for the Fiscal Year ended December 31, 2021
Financial Statements
Note 7 - Long Term Debt, page F-71
1.We note your response to prior comment one stating that you will "evaluate including
additional detail" regarding your long-term debt in future filings, although you also
indicate that you view your present disclosures as fully responsive to the disclosure
requirements in Rule 5-02.22 of Regulation S-X.
However, we believe that details should be provided for each issue or type of obligation
that is presently combined with dissimilar obligations and with greater specificity. Please
submit the revisions that you propose to address this concern.
FirstName LastNameGregory Anderson
Comapany NameAllegiant Travel CO
December 7, 2022 Page 2
FirstName LastName
Gregory Anderson
Allegiant Travel CO
December 7, 2022
Page 2
If you expect to include aggregated content, explain your rationale or view on the type
classification and provide us with a schedule of the related obligations, along with
descriptions of the corresponding balances and terms.
You may contact John Cannarella, Staff Accountant, at (202) 551-3337 if you have
questions regarding comments on the financial statements and related matters. Please contact
Karl Hiller, Branch Chief, at (202) 551-3686 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation