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October 30, 2023
Sudhanshu Priyadarshi
Chief Financial Officer
Keurig Dr Pepper Inc.
53 South Avenue
Burlington, Massachusetts 01803
Re:Keurig Dr Pepper Inc.
Form 10-K for the Year Ended December 31, 2022
Form 10-Q for the Quarter Ended September 30, 2023
Form 8-K furnished October 26, 2023
File No. 001-33829
Dear Sudhanshu Priyadarshi:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Year Ended December 31, 2022
Managements Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 29
1.Where you describe two or more business reasons that contributed to a material change in
a financial statement line item between periods, please quantify, where possible, the extent
to which each factor contributed to the overall change in that line item.  Please apply this
comment to both your consolidated and segment results of operations. As an example,
your disclosures on page 30 attribute the increase in selling, general and administrative
expenses to higher logistics costs, inflation, volume/mix impacts, increases in labor, and
unfavorable mark to market losses and only the mark to market loss is quantified.  See
Item 303 of Regulation S-K and SEC Release No. 33-8350.
Supplemental Guarantor Financial Information, page 41
2.We note that the summarized financial information disclosed for the Parent and

 FirstName LastNameSudhanshu Priyadarshi
 Comapany NameKeurig Dr Pepper Inc.
 October 30, 2023 Page 2
 FirstName LastNameSudhanshu Priyadarshi
Keurig Dr Pepper Inc.
October 30, 2023
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Guarantors includes net sales, income from operations and net income attributable to
KDP.  Please revise your disclosure in future filings to include the disclosure of gross
profit.  See Rule 13-01(a)(4) and Rule 1-02(bb)(1)(ii) of Regulation S-X.
Non-GAAP Financial Measures, page 42
3.We note that several of your adjusted measures include an adjustment for productivity.
Please tell us the nature of these productivity expenses adjustments and explain to us why
you do not believe these costs represent normal operating costs. See Question 100.01 in
the SEC Staff's Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.
Financial Statements
Notes to Consolidated Financial Statements
3. Goodwill and Other Intangible Assets
Impairment Analysis, page 70
4.We note that you performed an interim impairment analysis as of September 30, 2022,
recording a $311 million impairment and also performed your annual impairment analysis
as of October 1, 2022, recording a $161 million impairment.  Please address the
following:
•Summarize for us the changes in circumstances and/or assumptions that led to the
multiple impairment charges over a relatively short period of time.
•Explain the timing for recognizing the $161 million impairment and provide your
basis for concluding that this additional impairment did not exist as of September 30,
2022.
•Tell us whether your valuation assumptions changed between your September 30,
2022 and October 1, 2022 impairment tests.

Form 10-Q for the Quarter Ended September 30, 2023
Financial Statements
Notes to Condensed Consolidated Financial Statements
1. General
Reportable Segments, page 8
5.We note that effective January 1, 2023, you revised your segment structure to align with
changes in how the CODM manages the business, assesses performance and allocate
resources. We further note that the change resulted in three reportable segments from the
former four reportable segments.  Please explain to us in detail, the events that led to the
change in reportable segments.  For example, please tell us if there was a change in
segment managers that report to the CODM, level of detail of the financial information
reviewed by the CODM, or other factors that led to this change.  As part of your response,
please also tell us, and revise future filings to disclose, if in this new structure, any

 FirstName LastNameSudhanshu Priyadarshi
 Comapany NameKeurig Dr Pepper Inc.
 October 30, 2023 Page 3
 FirstName LastNameSudhanshu Priyadarshi
Keurig Dr Pepper Inc.
October 30, 2023
Page 3
operating segments have been aggregated into any of the reportable segments.  See
guidance in ASC 280-10-50-21.  If you have aggregated certain operating segments,
please provide us with a detailed analysis as to why you believe aggregation is consistent
with the criteria in ASC 280-10-50-11.
7. Revenue Recognition, page 19
6.We note that you have changed the level of disaggregation of revenue from five product
lines (CSD, NCB, K-Cup pods, Appliances, and Other), to four product lines (LRB, K-
Cup pods, Appliances and Other).  Please explain to us why you believe it is no longer
useful to disclose the CSD and NCB product lines, or any other product lines, but instead
combine them into the LRB line item.  As part of your response, please consider the
guidance in ASC 606-10-55-89 through 55-91.
Form 8-K furnished October 26, 2023
Exhibit 99.1 Earnings Release
Non-GAAP Financial Measures, page 4
7.Your disclosure indicates that the non-GAAP measures you present are adjusted gross
profit, adjusted operating income, adjusted net income, adjusted diluted EPS, and free
cash flow.  However, your reconciliations beginning on page A-6 also present adjusted
amounts for cost of sales, gross margin, SG&A, other income income, net, operating
margin, interest expense, loss on early extinguishment of debt, impairment of investments
and note receivable, other (income) expense, net, income before provision for income
taxes, provision (benefit) for income taxes, effective tax rate, EBITDA, Adjusted
EBITDA, and Management Leverage Ratio.  Please revise to identify all non-GAAP
measures and ensure the relevant disclosures of Item 10(e)(1)(i) are provided for each,
including a statement why management believes the presentation of the non-GAAP
financial measure provides useful information to investors regarding your financial
condition and results of operations.
Reconciliation of Certain Non-GAAP Information, page A-8
8.We note that on pages A-8 and A-12, you disclose adjusted income from operations by
segment, which is reconciled to the reported income from operations segment measure, by
presenting a column titled “Items Affecting Comparability.”  However, we also note that
although you detail the amounts included in Items Affecting Comparability earlier in the
press release on a consolidated basis, you have not provided detail of these adjustments
for each segment.  For segments that have a material amount of items affecting
comparability, please revise future filings to include detail of the nature and amount of
these adjustments.
Reconciliation of Adjusted EBITDA and Management Leverage Ratio, page A-13
9.Please note that EBITDA, by definition, should only reflect adjustments for interest, taxes,

 FirstName LastNameSudhanshu Priyadarshi
 Comapany NameKeurig Dr Pepper Inc.
 October 30, 2023 Page 4
 FirstName LastName
Sudhanshu Priyadarshi
Keurig Dr Pepper Inc.
October 30, 2023
Page 4
depreciation and amortization.  Either remove the Other (income) expense from your
calculation of EBITDA or revise to include the adjustment in your
Adjusted EBITDA calculation instead.  Refer to Question 103.01 of the SEC's
Compliance and Disclosure Interpretations on Non-GAAP Financial Measure for further
guidance.
            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 Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing