Correspondence 0001193125-24-214054 from JELD-WEN Holding, Inc. (JELD) (CIK 0001674335) (JELD)
JELD-WEN Holding, Inc. (JELD) (CIK 0001674335)
Date: Sept. 5, 2024 · CIK: 0001674335 · Accession: 0001193125-24-214054
AI Filing Summary & Sentiment
File numbers found in text: 001-38000
Referenced dates: August 30, 2024
Letter
Via EDGAR Division of Corporation Finance Office of Manufacturing Form 10-K for the Fiscal Year Ended December 31, 2023 Form 8-K filed February 20, 2024 Form 8-K filed May 6, 2024 File No. 001-38000
Dear Mr. Gordon and Ms. McConnell:
This letter contains the response of JELD-WEN Holding, Inc., a Delaware corporation (the “Company”), to your letter dated August 30, 2024, setting forth a comment of the Staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission regarding the above-referenced filings. For your convenience, we restated in italics the comment in the Staff’s comment letter.
Form 10-K for the fiscal year ended December 31, 2023
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Segment Results, page 45
1. We note your non-GAAP reconciliations of Adjusted EBITDA on pages 46 and 47 include a subtotal column that you identify as “Total Operating Segments.” Since each subtotal in this column represents a non-GAAP financial measure that would not comply with Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures, please revise your reconciliations in future filings to delete this subtotal column. This comment is also applicable to your presentation of this subtotal column in the Segment footnote, in earnings releases filed under Form 8-K, and in quarterly filings.
Response: The Company respectfully acknowledges the Staff’s comment and will remove the “Total Operating Segments” subtotal column in its non-GAAP reconciliations of Adjusted EBITDA in future periodic filings and earnings releases furnished on Form 8-K.
JELD-WEN, Inc. 2645 Silver Crescent Drive, Charlotte, NC 28273 USA www.jeld-wen.com
If you have any further questions or comments, please do not hesitate to contact the undersigned by telephone at (704) 264-5339. Thank you.
Sincerely,
/s/ Samantha Stoddard
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CORRESP 1 filename1.htm CORRESP September 5, 2024 Via EDGAR Mr. Jeffrey Gordon Ms. Anne McConnell Division of Corporation Finance Office of Manufacturing U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: JELD-WEN Holding, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Form 8-K filed February 20, 2024 Form 8-K filed May 6, 2024 File No. 001-38000 Dear Mr. Gordon and Ms. McConnell: This letter contains the response of JELD-WEN Holding, Inc., a Delaware corporation (the “Company”), to your letter dated August 30, 2024, setting forth a comment of the Staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission regarding the above-referenced filings. For your convenience, we restated in italics the comment in the Staff’s comment letter. Form 10-K for the fiscal year ended December 31, 2023 Management’s Discussion and Analysis of Financial Condition and Results of Operations Segment Results, page 45 1. We note your non-GAAP reconciliations of Adjusted EBITDA on pages 46 and 47 include a subtotal column that you identify as “Total Operating Segments.” Since each subtotal in this column represents a non-GAAP financial measure that would not comply with Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures, please revise your reconciliations in future filings to delete this subtotal column. This comment is also applicable to your presentation of this subtotal column in the Segment footnote, in earnings releases filed under Form 8-K, and in quarterly filings. Response: The Company respectfully acknowledges the Staff’s comment and will remove the “Total Operating Segments” subtotal column in its non-GAAP reconciliations of Adjusted EBITDA in future periodic filings and earnings releases furnished on Form 8-K. JELD-WEN, Inc. 2645 Silver Crescent Drive, Charlotte, NC 28273 USA www.jeld-wen.com If you have any further questions or comments, please do not hesitate to contact the undersigned by telephone at (704) 264-5339. Thank you. Sincerely, /s/ Samantha Stoddard Samantha Stoddard, Executive Vice President and Chief Financial Officer cc: William Christensen, Chief Executive Officer Michael Leon, Senior Vice President, Chief Accounting Officer Jas Hayes, Executive Vice President, General Counsel & Corporate Secretary Sid Shenoy, Partner, Womble Bond Dickinson (US) LLP