SEC Comment Letter 0000000000-24-007187 to Altice USA, Inc. (ATUS) (CIK 0001702780) (OPTU)
Altice USA, Inc. (ATUS) (CIK 0001702780)
Date: June 26, 2024 · CIK: 0001702780 · Accession: 0000000000-24-007187
AI Filing Summary & Sentiment
File numbers found in text: 001-38126
Letter
United States securities and exchange commission logo June 26, 2024 Marc Sirota Chief Financial Officer Altice USA, Inc. 1 Court Square West Long Island City, NY 11101 Re:Altice USA, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Response dated June 17, 2024 File No. 001-38126 Dear Marc Sirota: We have reviewed your June 17, 2024 response to our comment letter and have the following comment. 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 May 29, 2024 letter. Correspondence dated June 17, 2024 Form 10-K for the Fiscal Year Ended December 31, 2023, page 50 1.We note that you propose changing Operating Free Cash Flow to Adjusted EBITDA less Capital Expenditures. Adjusted EBITDA less Capital Expenditures is a Non-GAAP measure that combines attributes of both performance and liquidity measures (i.e. both accrual and cash items). Therefore, this measure violates the guidance in C&DI Question 100.01 that precludes presentation of a performance measure that excludes cash operating expenses. Please confirm that you will not disclose this measure in future filings.
FirstName LastNameMarc Sirota Comapany NameAltice USA, Inc. June 26, 2024 Page 2 FirstName LastName Marc Sirota Altice USA, Inc. June 26, 2024 Page 2 Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
June 26, 2024
Marc Sirota
Chief Financial Officer
Altice USA, Inc.
1 Court Square West
Long Island City, NY 11101
Re:Altice USA, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Response dated June 17, 2024
File No. 001-38126
Dear Marc Sirota:
We have reviewed your June 17, 2024 response to our comment letter and have the
following comment.
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 May 29,
2024 letter.
Correspondence dated June 17, 2024
Form 10-K for the Fiscal Year Ended December 31, 2023, page 50
1.We note that you propose changing Operating Free Cash Flow to Adjusted EBITDA less
Capital Expenditures. Adjusted EBITDA less Capital Expenditures is a Non-GAAP
measure that combines attributes of both performance and liquidity measures (i.e. both
accrual and cash items). Therefore, this measure violates the guidance in C&DI Question
100.01 that precludes presentation of a performance measure that excludes cash operating
expenses. Please confirm that you will not disclose this measure in future filings.
FirstName LastNameMarc Sirota
Comapany NameAltice USA, Inc.
June 26, 2024 Page 2
FirstName LastName
Marc Sirota
Altice USA, Inc.
June 26, 2024
Page 2
Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology