Correspondence 0001193125-24-282628 from Playa Hotels & Resorts N.V. (CIK 0001692412)
Playa Hotels & Resorts N.V. (CIK 0001692412)
Date: Dec. 20, 2024 · CIK: 0001692412 · Accession: 0001193125-24-282628
AI Filing Summary & Sentiment
File numbers found in text: 001-38012
Referenced dates: December 18, 2024
Letter
VIA EDGAR Division of Corporation Finance Office of Real Estate & Construction Re: Playa Hotels & Resorts N.V. Form 10-K for the fiscal year ended December 31, 2023 Form 8-K filed November 6, 2024 File No. 001-38012
Dear Mr. Lewis and Mr. Esquivel:
We are writing in response to your letter dated December 18, 2024, commenting on the above-referenced filings of Playa Hotels & Resorts N.V. (“Playa” or the “Company”). For your convenience, we have repeated the staff’s comment below, followed by our response to the comment.
Form 8-K filed November 6, 2024
Exhibit 99.1, page 3
Comment:
1. We note your discussion of Adjusted EBITDA you expect to achieve for fiscal year 2024 without providing a reconciliation to the most directly comparable GAAP measure. To the extent this measure is presented in future filings, please provide such reconciliation or a statement that the information could not be presented without unreasonable effort. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10(b) of the Compliance & Disclosure Interpretations (“C&DIs”) for Non-GAAP Financial Measures.
Response:
The Company respectfully acknowledges the staff’s comment and will revise its discussion of Adjusted EBITDA guidance, to the extent the measure is presented in future filings, to include a reconciliation to the most directly comparable GAAP measure or a statement that the information could not be presented without unreasonable effort.
*****
Thank you for your consideration in reviewing the above response. Please direct any further comments or requests for additional information to my attention at Ryan.Hymel@playaresorts.com.
Sincerely,
Playa Hotels & Resorts N.V.
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CORRESP 1 filename1.htm CORRESP December 20, 2024 VIA EDGAR Mr. Jeffrey Lewis Mr. Isaac Esquivel Division of Corporation Finance Office of Real Estate & Construction U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Playa Hotels & Resorts N.V. Form 10-K for the fiscal year ended December 31, 2023 Form 8-K filed November 6, 2024 File No. 001-38012 Dear Mr. Lewis and Mr. Esquivel: We are writing in response to your letter dated December 18, 2024, commenting on the above-referenced filings of Playa Hotels & Resorts N.V. (“Playa” or the “Company”). For your convenience, we have repeated the staff’s comment below, followed by our response to the comment. Form 8-K filed November 6, 2024 Exhibit 99.1, page 3 Comment: 1. We note your discussion of Adjusted EBITDA you expect to achieve for fiscal year 2024 without providing a reconciliation to the most directly comparable GAAP measure. To the extent this measure is presented in future filings, please provide such reconciliation or a statement that the information could not be presented without unreasonable effort. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10(b) of the Compliance & Disclosure Interpretations (“C&DIs”) for Non-GAAP Financial Measures. Response: The Company respectfully acknowledges the staff’s comment and will revise its discussion of Adjusted EBITDA guidance, to the extent the measure is presented in future filings, to include a reconciliation to the most directly comparable GAAP measure or a statement that the information could not be presented without unreasonable effort. ***** 1 Thank you for your consideration in reviewing the above response. Please direct any further comments or requests for additional information to my attention at Ryan.Hymel@playaresorts.com. Sincerely, Playa Hotels & Resorts N.V. /s/ Ryan Hymel Ryan Hymel EVP & Chief Financial Officer cc: Michael E. McTiernan, Hogan Lovells US LLP 2