SEC Company Response from LINDBLAD EXPEDITIONS HOLDINGS, INC. (LIND) (CIK 0001512499) (LIND) — Jul 2, 2019
LINDBLAD EXPEDITIONS HOLDINGS, INC. (LIND) (CIK 0001512499)
Date: July 2, 2019 · CIK: 0001512499 · Accession: 0001437749-19-013286
AI Filing Summary & Sentiment
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Transportation and Leisure Washington, D.C. 20549 Attention: Ms. Effie Simpson Ms. Claire Erlanger
Dear Ms. Simpson and Ms. Erlanger:
Based on discussions with the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”), Lindblad Expeditions Holdings, Inc. (the “Company”, “Lindblad” or “we”) submit the following further disclosure example related to the financial outlook section of the Company’s earnings release and the Staff’s previous comment.
Reconciliation of forecasted income before income taxes to Adjusted EBITDA:
(in millions)
Full Year 2019
Income before income taxes
$
to
$
Depreciation and amortization
to
Interest expense, net
to
Stock-based compensation
to
National Geographic fee amortization
to
Other
-
to
Adjusted EBITDA
$
to
$
A reconciliation of net income to Adjusted EBITDA is not provided because the Company cannot estimate or predict with reasonable certainty certain discrete tax items, which could significantly impact that financial measure.
*****
I hereby confirm on behalf of Lindblad Expeditions Holdings, Inc. that:
●
Lindblad Expeditions Holdings, Inc. is responsible for the adequacy and accuracy of the disclosure in the filing;
●
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and
●
Lindblad Expeditions Holdings, Inc. may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact either Tom Naiman of the Company at (212) 261-9050, or me at (212) 261-9008 if you have any questions or comments relating to the matters referenced above. Thank you for your attention to this matter.
Sincerely,
/s/ Craig I. Felenstein
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CORRESP 1 filename1.htm lindb20190701_corresp.htm LINDBLAD EXPEDITIONS HOLDINGS, INC. 96 Morton Street, 9th Floor New York, NY 10014 July 1, 2019 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Transportation and Leisure 100 F Street, N.E. Washington, D.C. 20549 Attention: Ms. Effie Simpson Ms. Claire Erlanger Dear Ms. Simpson and Ms. Erlanger: Based on discussions with the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”), Lindblad Expeditions Holdings, Inc. (the “Company”, “Lindblad” or “we”) submit the following further disclosure example related to the financial outlook section of the Company’s earnings release and the Staff’s previous comment. Reconciliation of forecasted income before income taxes to Adjusted EBITDA: (in millions) Full Year 2019 Income before income taxes $ 22 to $ 25 Depreciation and amortization 26 to 25 Interest expense, net 12 to 12 Stock-based compensation 4 to 4 National Geographic fee amortization 3 to 3 Other - to 1 Adjusted EBITDA $ 67 to $ 70 A reconciliation of net income to Adjusted EBITDA is not provided because the Company cannot estimate or predict with reasonable certainty certain discrete tax items, which could significantly impact that financial measure. ***** I hereby confirm on behalf of Lindblad Expeditions Holdings, Inc. that: ● Lindblad Expeditions Holdings, Inc. is responsible for the adequacy and accuracy of the disclosure in the filing; ● Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and ● Lindblad Expeditions Holdings, Inc. may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact either Tom Naiman of the Company at (212) 261-9050, or me at (212) 261-9008 if you have any questions or comments relating to the matters referenced above. Thank you for your attention to this matter. Sincerely, /s/ Craig I. Felenstein Craig I. Felenstein Chief Financial Officer Lindblad Expeditions Holdings, Inc. cc: Tom Naiman, Director Technical Accounting