Correspondence 0001616000-24-000068 from Xenia Hotels & Resorts, Inc. (XHR) (CIK 0001616000) (XHR)
Xenia Hotels & Resorts, Inc. (XHR) (CIK 0001616000)
Date: June 7, 2024 · CIK: 0001616000 · Accession: 0001616000-24-000068
AI Filing Summary & Sentiment
File numbers found in text: 001-36594
Referenced dates: June 3, 2024
Letter
Document
June 7, 2024
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: Eric McPhee
Jennifer Monick
Re: Xenia Hotels & Resorts, Inc.
Form 10-K for the year ended December 31, 2023
Form 8-K filed May 2, 2024
File No. 001-36594
Ladies and Gentlemen:
Set forth below is the response of Xenia Hotels & Resorts, Inc (the “Company”), to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in the letter dated June 3, 2024 relating to Exhibit 99.1 to the Company’s Form 8-K filed on May 2, 2024 (the “Form 8-K”).
For ease of reference, the text of the comment in the Staff’s letter has been reproduced in italics herein, with the Company’s response immediately following. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Form 8-K.
Form 8-K filed May 2, 2024
Exhibit 99.1
Operating Results, page 2
1.We have reviewed your response to comment 1. This measure appears to exclude amounts that are included in the most directly comparable measure calculated and presented in accordance with GAAP (i.e., Net Income); thus, Same-Property Hotel Net Income appears to be a non-GAAP measure. To the extent you continue to disclose this measure in future earnings releases or other future filings, please confirm you will include the disclosures required by Item 10(e) of Regulation S-K.
Response: The Company respectfully advises the Staff that, in response to the Staff’s comment, the Company intends to remove the reference to Same-Property Hotel Net Income in future earnings releases. In the event the Company discloses Same-Property Hotel Net Income in future earnings releases or future filings, the Company will include the disclosures required by Item 10(e) of Regulation S-K.
* * *
Should you have any comments or questions regarding the foregoing, please feel free to call me at 407-246-8100. Thank you in advance for your attention to this matter.
Sincerely,
/s/ Atish Shah
Show Raw Text
CORRESP 1 filename1.htm Document June 7, 2024 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, D.C. 20549-6010 Attention: Eric McPhee Jennifer Monick Re: Xenia Hotels & Resorts, Inc. Form 10-K for the year ended December 31, 2023 Form 8-K filed May 2, 2024 File No. 001-36594 Ladies and Gentlemen: Set forth below is the response of Xenia Hotels & Resorts, Inc (the “Company”), to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in the letter dated June 3, 2024 relating to Exhibit 99.1 to the Company’s Form 8-K filed on May 2, 2024 (the “Form 8-K”). For ease of reference, the text of the comment in the Staff’s letter has been reproduced in italics herein, with the Company’s response immediately following. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Form 8-K. Form 8-K filed May 2, 2024 Exhibit 99.1 Operating Results, page 2 1.We have reviewed your response to comment 1. This measure appears to exclude amounts that are included in the most directly comparable measure calculated and presented in accordance with GAAP (i.e., Net Income); thus, Same-Property Hotel Net Income appears to be a non-GAAP measure. To the extent you continue to disclose this measure in future earnings releases or other future filings, please confirm you will include the disclosures required by Item 10(e) of Regulation S-K. Response: The Company respectfully advises the Staff that, in response to the Staff’s comment, the Company intends to remove the reference to Same-Property Hotel Net Income in future earnings releases. In the event the Company discloses Same-Property Hotel Net Income in future earnings releases or future filings, the Company will include the disclosures required by Item 10(e) of Regulation S-K. * * * Should you have any comments or questions regarding the foregoing, please feel free to call me at 407-246-8100. Thank you in advance for your attention to this matter. Sincerely, /s/ Atish Shah Atish Shah Executive Vice President, Chief Financial Officer and Treasurer cc: Taylor C. Kessel, Senior Vice President, General Counsel and Secretary Joseph T. Johnson, Senior Vice President and Chief Accounting Officer Cathy Birkeland, Latham & Watkins LLP Joel H. Trotter, Latham & Watkins LLP