SEC Comment Letter for Spirit Aviation Holdings, Inc. (FLYY) (CIK 0001498710) (FLYYQ) — Jul 24, 2017
Spirit Aviation Holdings, Inc. (FLYY) (CIK 0001498710)
Date: July 24, 2017 · CIK: 0001498710 · Accession: 0000000000-17-025886
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 July 24 , 2017 Edward M. Christie Chief Financial Officer Spirit Airlines, Inc. 2800 Executive Way Miramar, Florida 33025
Re: Spirit Airlines, Inc. Form 10-K for Fiscal Year Ended December 31, 2016 Filed February 13 , 2017 Form 8 -K Filed 4/28/2017 File No. 001 -35186
Dear Mr. Christie :
We have limited our review of your filing to the financial statements and related disclosures 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 busine ss days by providing the request ed information or advis e 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.
Form 8 -K filed 4/28/2017
Exhibit 99.1, Page 11
1. We note you present a measure titled “Return on Invested Capital.” This measure uses a non-GAAP amount (Adjusted Operating Profit) in its calculation. Accordingly, please revise to retitle this measure to make it clear it is a non -GAAP measure to prevent confusion with computations of ROIC based solely on GAAP amounts.
2. You include in your computation of ROIC “capitalized aircraft operating leases (7x Aircraft Rent).” Pl ease explain to us and disclose the basis for this amount and why the multiple of 7 is representative and reasonable in your circumstances .
Edward M. Christie Spirit Airlines, Inc. July 24 , 2017 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosure s, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Aamira Chaudhry at 202 -551-3389 or Doug Jones at 202 -551-3309 if you have questions regarding comments on the financial statements and related matters. Please contact me at 202 -551-3380 with any other questions.
Sincerely,
/s/ Lyn Shenk
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Mail Stop 3561
July 24 , 2017
Edward M. Christie
Chief Financial Officer
Spirit Airlines, Inc.
2800 Executive Way
Miramar, Florida 33025
Re: Spirit Airlines, Inc.
Form 10-K for Fiscal Year Ended December 31, 2016
Filed February 13 , 2017
Form 8 -K
Filed 4/28/2017
File No. 001 -35186
Dear Mr. Christie :
We have limited our review of your filing to the financial statements and related
disclosures 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 busine ss days by providing the request ed
information or advis e 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.
Form 8 -K filed 4/28/2017
Exhibit 99.1, Page 11
1. We note you present a measure titled “Return on Invested Capital.” This measure uses a
non-GAAP amount (Adjusted Operating Profit) in its calculation. Accordingly, please
revise to retitle this measure to make it clear it is a non -GAAP measure to prevent
confusion with computations of ROIC based solely on GAAP amounts.
2. You include in your computation of ROIC “capitalized aircraft operating leases (7x
Aircraft Rent).” Pl ease explain to us and disclose the basis for this amount and why the
multiple of 7 is representative and reasonable in your circumstances .
Edward M. Christie
Spirit Airlines, Inc.
July 24 , 2017
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosure s, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Aamira Chaudhry at 202 -551-3389 or Doug Jones at 202 -551-3309 if
you have questions regarding comments on the financial statements and related matters. Please
contact me at 202 -551-3380 with any other questions.
Sincerely,
/s/ Lyn Shenk
Lyn Shenk
Branch Chief
Office of Transportation and Leisure