SEC Comment Letter 0000000000-24-011530 to LINDBLAD EXPEDITIONS HOLDINGS, INC. (LIND)
LINDBLAD EXPEDITIONS HOLDINGS, INC.
Date: Oct. 10, 2024 · CIK: 0001512499 · Accession: 0000000000-24-011530
AI Filing Summary & Sentiment
File numbers found in text: 001-35898
Referenced dates: October 2, 2024
Letter
October 10, 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 Response Letter dated October 2, 2024 File No. 001-35898 Dear Dyson Dryden: We have reviewed your October 2, 2024 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our September 23, 2024 letter. Form 10-K for the Fiscal Year ended December 31, 2023 Management's Discussion and Analysis Results of Operations, page 44 We note that you have proposed adding disclosures of the percentage changes in occupancy, the number of trips, and revenue per guest, in your discussion of consolidated revenues in response to prior comment one, concerning the requirement in Item 303(b)(2)(iii) of Regulation S-K, to disclose the extent to which material changes in revenues are attributable to changes in prices, changes in the volume of services, or to the introduction of new services during the period.
However, while it is helpful to understand the percentage changes in the underlying volumetric and price factors, you would also need to quantify the extent to which 1.
October 10, 2024 Page 2 revenues have changed due to changes in both volumetric and price factors to comply with the aforementioned requirement. We reissue prior comment one.
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
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October 10, 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
Response Letter dated October 2, 2024
File No. 001-35898
Dear Dyson Dryden:
We have reviewed your October 2, 2024 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in our
September 23, 2024 letter.
Form 10-K for the Fiscal Year ended December 31, 2023
Management's Discussion and Analysis
Results of Operations, page 44
We note that you have proposed adding disclosures of the percentage changes in
occupancy, the number of trips, and revenue per guest, in your discussion of
consolidated revenues in response to prior comment one, concerning the requirement
in Item 303(b)(2)(iii) of Regulation S-K, to disclose the extent to which material
changes in revenues are attributable to changes in prices, changes in the volume of
services, or to the introduction of new services during the period.
However, while it is helpful to understand the percentage changes in the underlying
volumetric and price factors, you would also need to quantify the extent to which 1.
October 10, 2024
Page 2
revenues have changed due to changes in both volumetric and price factors to comply
with the aforementioned requirement. We reissue prior comment one.
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