SEC Comment Letter for Grand Canyon Education, Inc. (LOPE) (CIK 0001434588) (LOPE) — Sep 23, 2022
Grand Canyon Education, Inc. (LOPE) (CIK 0001434588)
Date: Sept. 23, 2022 · CIK: 0001434588 · Accession: 0000000000-22-010488
AI Filing Summary & Sentiment
File numbers found in text: 001-34211
Letter
United States securities and exchange commission logo September 22, 2022 Daniel Bachus Chief Financial Officer Grand Canyon Education, Inc. 2600 W. Camelback Road Phoenix AZ 85017 Re:Grand Canyon Education, Inc. Form 10-K for Fiscal Year Ended December 31, 2021 Form 8-K Furnished August 4, 2022 Response dated September 9, 2022 File No. 001-34211 Dear Mr. Bachus: We have reviewed your September 9, 2022 response to our comment letter and have the following comment. Our comment, ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 26, 2022 letter. Response dated September 9, 2022 Form 8-K Furnished August 4, 2022 Exhibit 99.1 2022 Outlook, page 7 1.Your proposed narrative description of the calculation of the non-GAAP measures "as adjusted operating margin" and "as adjusted diluted EPS" does not appear to provide investors with enough information to reconcile to the comparable GAAP measures without unreasonable effort. In this regard, please consider providing a schedule for the reconciliation.
FirstName LastNameDaniel Bachus Comapany NameGrand Canyon Education, Inc. September 22, 2022 Page 2 FirstName LastName Daniel Bachus Grand Canyon Education, Inc. September 22, 2022 Page 2
You may contact Patrick Kuhn at (202) 551-3308 or Doug Jones at (202) 551-3309 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
September 22, 2022
Daniel Bachus
Chief Financial Officer
Grand Canyon Education, Inc.
2600 W. Camelback Road
Phoenix AZ 85017
Re:Grand Canyon Education, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Form 8-K Furnished August 4, 2022
Response dated September 9, 2022
File No. 001-34211
Dear Mr. Bachus:
We have reviewed your September 9, 2022 response to our comment letter and have the
following comment. Our comment, ask you to provide us with information so we may better
understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
August 26, 2022 letter.
Response dated September 9, 2022
Form 8-K Furnished August 4, 2022
Exhibit 99.1
2022 Outlook, page 7
1.Your proposed narrative description of the calculation of the non-GAAP measures "as
adjusted operating margin" and "as adjusted diluted EPS" does not appear to provide
investors with enough information to reconcile to the comparable GAAP
measures without unreasonable effort. In this regard, please consider providing a
schedule for the reconciliation.
FirstName LastNameDaniel Bachus
Comapany NameGrand Canyon Education, Inc.
September 22, 2022 Page 2
FirstName LastName
Daniel Bachus
Grand Canyon Education, Inc.
September 22, 2022
Page 2
You may contact Patrick Kuhn at (202) 551-3308 or Doug Jones at (202) 551-3309 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services