SEC Comment Letter for Spirit Aviation Holdings, Inc. (FLYY) (CIK 0001498710) (FLYYQ) — Feb 4, 2022
Spirit Aviation Holdings, Inc. (FLYY) (CIK 0001498710)
Date: Feb. 4, 2022 · CIK: 0001498710 · Accession: 0000000000-22-001417
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-35186
Referenced dates: December 10, 2021
Letter
United States securities and exchange commission logo February 4, 2022 Scott M. Haralson Chief Financial Officer Spirit Airlines, Inc. 2800 Executive Way Miramar, FL 33025 Re:Spirit Airlines, Inc. Form 10-K for Fiscal Year Ended December 31, 2020 Filed February 10, 2021 Form 8-K filed October 27, 2021 File No. 001-35186 Dear Mr. Haralson: We have reviewed your December 10, 2021 response to our comment letter 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 business days by providing the requested information or advise 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. Unless we note otherwise, our references to prior comments are to comments in our December 3, 2021 letter. Response Letter Dated December 10, 2021 Form 8-K filed October 27, 2021 Exhibit 99.1 Non-GAAP Financial Measures, page 10 1.We note your response to our prior comment 1. It appears your non-GAAP financial measures that include adjustments for lease return costs should be revised as these appear to be cash operating expenses.
FirstName LastNameScott M. Haralson Comapany NameSpirit Airlines, Inc. February 4, 2022 Page 2 FirstName LastName Scott M. Haralson Spirit Airlines, Inc. February 4, 2022 Page 2 You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Kimberly Calder, Assistant Chief Accountant, at (202) 551-3701 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
February 4, 2022
Scott M. Haralson
Chief Financial Officer
Spirit Airlines, Inc.
2800 Executive Way
Miramar, FL 33025
Re:Spirit Airlines, Inc.
Form 10-K for Fiscal Year Ended December 31, 2020
Filed February 10, 2021
Form 8-K filed October 27, 2021
File No. 001-35186
Dear Mr. Haralson:
We have reviewed your December 10, 2021 response to our comment letter 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 business days by providing the requested
information or advise 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. Unless we note otherwise, our references to prior comments are to comments in our
December 3, 2021 letter.
Response Letter Dated December 10, 2021
Form 8-K filed October 27, 2021
Exhibit 99.1
Non-GAAP Financial Measures, page 10
1.We note your response to our prior comment 1. It appears your non-GAAP financial
measures that include adjustments for lease return costs should be revised as these appear
to be cash operating expenses.
FirstName LastNameScott M. Haralson
Comapany NameSpirit Airlines, Inc.
February 4, 2022 Page 2
FirstName LastName
Scott M. Haralson
Spirit Airlines, Inc.
February 4, 2022
Page 2
You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Kimberly Calder,
Assistant Chief Accountant, at (202) 551-3701 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation