SEC Comment Letter 0000000000-23-013632 to Keurig Dr Pepper Inc. (KDP) (CIK 0001418135) (KDP)
Keurig Dr Pepper Inc. (KDP) (CIK 0001418135)
Date: Dec. 14, 2023 · CIK: 0001418135 · Accession: 0000000000-23-013632
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File numbers found in text: 001-33829
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United States securities and exchange commission logo
December 14, 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
Filed February 23, 2023
File No. 001-33829
Dear Sudhanshu Priyadarshi:
We have reviewed your November 30, 2023 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 October 30,
2023 letter.
Form 10-K for the Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 42
1.We note your response to prior comment three. Considering the costs in the response
appear to be startup costs of new manufacturing lines and appear to represent normal,
recurring, cash operating expenses necessary to operate your business, please remove
these adjustments from future filings. Refer to Question 100.01 of the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameSudhanshu Priyadarshi
Comapany NameKeurig Dr Pepper Inc.
December 14, 2023 Page 2
FirstName LastName
Sudhanshu Priyadarshi
Keurig Dr Pepper Inc.
December 14, 2023
Page 2
Please contact Heather Clark at 202-551-3624 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing