Correspondence 0000950170-24-100787 from Yum China Holdings, Inc. (YUMC)
Yum China Holdings, Inc.
Date: Aug. 27, 2024 · CIK: 0001673358 · Accession: 0000950170-24-100787
AI Filing Summary & Sentiment
File numbers found in text: 001-37762
Referenced dates: July 16, 2024
Letter
August 27, 2024
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Ta Tanisha Meadows
Adam Phippen
Re:
Yum China Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-37762
Ladies and Gentlemen:
Yum China Holdings, Inc. (the “Company”) is pleased to respond to the letter dated July 16, 2024 from the staff (the “Staff”) of the Securities and Exchange Commission (“Commission”) with respect to the Company’s annual report on Form 10-K for the year ended December 31, 2023. For the convenience of the Staff’s review, we have set forth below the comment contained in the Staff’s letter in italics followed by the Company’s response.
Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 66
1. Wherever you present Restaurant margin, please also disclose with equal or greater prominence, the most directly comparable financial measure or measures calculated and presented in accordance with GAAP. Refer to Item 10(e)(1)(i)(A) of Regulation S-K.
Company Response:
The Company acknowledges the Staff’s comment. In future filings, the Company will disclose the most comparable GAAP measure “OP Margin %” with equal or greater prominence. It will be added immediately after “Operating Profit” in the revised table on page 66 of our 2023 Form 10-K. Additionally, “OP Margin %” will be presented before “Restaurant margin %” wherever the non-GAAP measure “Restaurant margin %” is discussed.
*****
Thank you for your consideration in reviewing the above response. Please contact me at Pingping.Liu@YumChina.com with any questions.
Sincerely,
/s/ Pingping Liu
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CORRESP
August 27, 2024
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Ta Tanisha Meadows
Adam Phippen
Re:
Yum China Holdings, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-37762
Ladies and Gentlemen:
Yum China Holdings, Inc. (the “Company”) is pleased to respond to the letter dated July 16, 2024 from the staff (the “Staff”) of the Securities and Exchange Commission (“Commission”) with respect to the Company’s annual report on Form 10-K for the year ended December 31, 2023. For the convenience of the Staff’s review, we have set forth below the comment contained in the Staff’s letter in italics followed by the Company’s response.
Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 66
1. Wherever you present Restaurant margin, please also disclose with equal or greater prominence, the most directly comparable financial measure or measures calculated and presented in accordance with GAAP. Refer to Item 10(e)(1)(i)(A) of Regulation S-K.
Company Response:
The Company acknowledges the Staff’s comment. In future filings, the Company will disclose the most comparable GAAP measure “OP Margin %” with equal or greater prominence. It will be added immediately after “Operating Profit” in the revised table on page 66 of our 2023 Form 10-K. Additionally, “OP Margin %” will be presented before “Restaurant margin %” wherever the non-GAAP measure “Restaurant margin %” is discussed.
*****
Thank you for your consideration in reviewing the above response. Please contact me at Pingping.Liu@YumChina.com with any questions.
Sincerely,
/s/ Pingping Liu
Pingping Liu
Chief Legal Officer
cc:
Sonia Barros, Sidley Austin LLP
Sara Von Althann, Sidley Austin LLP