SEC Comment Letter 0000000000-24-011722 to ONE Group Hospitality, Inc. (STKS) (CIK 0001399520) (STKS)
ONE Group Hospitality, Inc. (STKS) (CIK 0001399520)
Date: Oct. 18, 2024 · CIK: 0001399520 · Accession: 0000000000-24-011722
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File numbers found in text: 001-37379
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October 18, 2024
Tyler Loy
Chief Financial Officer
The ONE Group Hospitality, Inc.
1624 Market Street, Suite 311
Denver, CO 80202
Re:The ONE Group Hospitality, Inc.
Form 10-K for the Fiscal Year ended December 31, 2023
Response dated October 4, 2024
File No. 001-37379
Dear Tyler Loy:
We have reviewed your October 4, 2024 response to our comment letter and have the
following comment(s).
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.
Unless we note otherwise, any references to prior comments are to comments in our
September 20, 2024 letter.
Form 8-K filed August 6, 2024
Highlights for second quarter 2024 compared to the same quarter in 2023, page 1
1.We note your response to prior comments 1 and 3 and reissue comment 3, in part. Net
income does not appear to be the most directly comparable measure to Restaurant
Operating Profit and Restaurant Operating Profit Margin. Please present the most
directly comparable GAAP measures with equal or greater prominence. Refer to
Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
October 18, 2024
Page 2
Please contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at 202-551-
3336 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services