SecProbe.io

September 23, 2024
Dyson Dryden
Chief Financial Officer
Lindblad Expeditions Holdings, Inc.
96 Morton Street, 9th Floor
New York, New York 10014
Re:Lindblad Expeditions Holdings, Inc.
Form 10-K for the Fiscal Year ended December 31, 2023
Filed March 6, 2024
File No. 001-35898
Dear Dyson Dryden:
            We have reviewed your filing and have the following comments.
            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 Fiscal Year ended December 31, 2023
Management's Discussion and Analysis
Results of Operations, page 44
Please expand your discussion and analysis of consolidated and segment revenues to
clarify the extent to which changes in revenues are attributable to changes in volumes and
separately to changes in prices to comply with Item 303(b)(2)(iii) of Regulation S-K.

Given that your Land Experiences segment generated 30% of total revenues and 182% of
total operating income for 2023, please also expand your discussion and analysis to
include material non-financial metrics for this segment, such as the number of expeditions
and trips for each period, and to address the relative significance of the four land-based
brands, i.e. Natural Habitat, DuVine, Off the Beaten Path and Classic Journeys, to the
segment results to comply with Item 303(a) and (b)(2)(i) of Regulation S-K.

Please submit the revisions that you propose to address these concerns. However, if you
do not believe this information would be relevant to an assessment or material to an
understanding of your results of operations, tell us how you formulated your view and 1.

September 23, 2024
Page 2
provide us with details about the revenues and earnings of the components.

Financial Statements
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition, page F-11
2.We note that you provide some information about disaggregated revenues along with your
accounting policy note, including various percentages of total revenues for the four
categories that comprise guest ticket revenues, and one category for other tour revenue.

Please expand your disclosure to explain how this information correlates with revenues
reported for each segment on page F-31, and to include the dollar values associated with
each category to comply with FASB ASC 606-10-50-5 and 6.

            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 Lily Dang at 202-551-3867 or Karl Hiller at 202-551-3686 if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation