SEC Comment Letter 0000000000-24-009535 to Hilton Worldwide Holdings Inc. (HLT)
Hilton Worldwide Holdings Inc.
Date: Aug. 20, 2024 · CIK: 0001585689 · Accession: 0000000000-24-009535
AI Filing Summary & Sentiment
File numbers found in text: 001-36243
Letter
August 20, 2024 Michael Duffy Senior Vice President, Chief Accounting and Risk Officer Hilton Worldwide Holdings Inc. 7930 Jones Branch Drive, Suite 1100 McLean, VA 22102 Re:Hilton Worldwide Holdings Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Response dated June 18, 2024 File No. 001-36243 Dear Michael Duffy: We have reviewed your June 18, 2024 response to our comment letter and have the following comment. 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 June 11, 2024 letter. Form 10-K for the Fiscal Year Ended December 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations EBITDA and Adjusted EBITDA, page 48 1.We have considered your responses to prior comments 1 and 2. We observe that the adjustment for “net other expenses from managed and franchised properties” to arrive at Adjusted EBITDA and Net income, adjusted for special items and the adjustment for "other revenues from managed and franchised properties" to arrive at Total revenues, as adjusted appear to change the pattern of recognition of revenue and expense as prescribed by GAAP, resulting in tailored non-GAAP measures. In this regard, please tell us how you considered Question 100.04 of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations in your determination that it is appropriate to present these adjustments.
August 20, 2024 Page 2 Please contact Frank Knapp at 202-551-3805 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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August 20, 2024
Michael Duffy
Senior Vice President, Chief Accounting and Risk Officer
Hilton Worldwide Holdings Inc.
7930 Jones Branch Drive, Suite 1100
McLean, VA 22102
Re:Hilton Worldwide Holdings Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Response dated June 18, 2024
File No. 001-36243
Dear Michael Duffy:
We have reviewed your June 18, 2024 response to our comment letter and have the
following comment.
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 June 11, 2024 letter.
Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
EBITDA and Adjusted EBITDA, page 48
1.We have considered your responses to prior comments 1 and 2. We observe that the
adjustment for “net other expenses from managed and franchised properties” to arrive at
Adjusted EBITDA and Net income, adjusted for special items and the adjustment for
"other revenues from managed and franchised properties" to arrive at Total revenues, as
adjusted appear to change the pattern of recognition of revenue and expense as prescribed
by GAAP, resulting in tailored non-GAAP measures. In this regard, please tell us how
you considered Question 100.04 of the Non-GAAP Financial Measures Compliance
& Disclosure Interpretations in your determination that it is appropriate to present these
adjustments.
August 20, 2024
Page 2
Please contact Frank Knapp at 202-551-3805 or Jennifer Monick at 202-551-3295 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction