SEC Comment Letter 0000000000-23-012879 to Summit Materials, Inc. (SUM) (CIK 0001621563)
Summit Materials, Inc. (SUM) (CIK 0001621563)
Date: Nov. 27, 2023 · CIK: 0001621563 · Accession: 0000000000-23-012879
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File numbers found in text: 001-36873
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United States securities and exchange commission logo
November 27, 2023
Anne P. Noonan
President and Chief Executive Officer
Summit Materials, Inc.
1801 California Street
Suite 3500
Denver, CO 80202
Re:Summit Materials, Inc.
Revised Preliminary Proxy Statement on Schedule 14A
Filed November 11, 2023
File No. 001-36873
Dear Anne P. Noonan:
We have reviewed your November 13, 2023 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 November 8, 2023
letter.
Revised Preliminary Proxy Statement on Schedule 14A Filed November 13, 2023
Unaudited pro forma condensed combined financial information, page 100
1.Please update the pro forma information as of the date of the most recent financial
statements included in the proxy statement. Refer to Rule 11-02(c)(1) of Regulation S-X.
Where You Can Find Additional Information; Incorporation of Certain Documents by Referece,
page 113
2.Please revise to incorporate by reference your Form 10-Q for the Fiscal Quarter Ended
September 30, 2023 filed on November 2, 2023.
FirstName LastNameAnne P. Noonan
Comapany NameSummit Materials, Inc.
November 27, 2023 Page 2
FirstName LastName
Anne P. Noonan
Summit Materials, Inc.
November 27, 2023
Page 2
Financial Statments
Argos North America Corp, page F-1
3.Please note the requirement to update target company financial statements is based on the
registrant’s obligation to update under Rule 3-12 of Regulation S-X. Therefore, please
update the financial statements of Argos North America Corp as of and for the nine
months ended September 30, 2023.
Please contact Michael Purcell at 202-551-5351 or Kevin Dougherty at 202-551-3271
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Evan Rosen