SEC Comment Letter 0000000000-23-001607 to Berry Corp (bry) (CIK 0001705873)
Berry Corp (bry) (CIK 0001705873)
Date: Feb. 16, 2023 · CIK: 0001705873 · Accession: 0000000000-23-001607
AI Filing Summary & Sentiment
File numbers found in text: 001-38606
Referenced dates: December 14, 2022, November 4, 2022
Letter
United States securities and exchange commission logo February 16, 2023 Michael S. Helm Chief Financial Officer and Chief Accounting Officer Berry Corporation (bry) 16000 Dallas Parkway, Suite 500 Dallas, Texas 75248 Re:Berry Corporation (bry) Form 10-K for Fiscal Year Ended December 31, 2021 Response dated January 13, 2023 File No. 001-38606 Dear Michael S. Helm: We have reviewed your January 13, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 14, 2022 letter. Form 10-K for Fiscal Year Ended December 31, 2021 Management's Discussion and Analysis of Financial Condition and Results of Operations How We Plan and Evaluate Operations Operating Expenses, page 70 1.We have considered your responses to comment 1 in our letter dated November 4, 2022 and comment 1 in our letter dated December 14, 2022. However, we do not believe that the presentation of the measure Operating Expenses, or the alternatively titled measure and presentation you have proposed, is appropriate. Please revise your presentation as necessary. Non-GAAP Financial Measures, page 91 2.We note from your response to prior comment 3 that your reconciliations of Basic and
FirstName LastNameMichael S. Helm Comapany NameBerry Corporation (bry) February 16, 2023 Page 2 FirstName LastName Michael S. Helm Berry Corporation (bry) February 16, 2023 Page 2 Diluted EPS on Adjusted Net Income (Loss) per share will not be provided on a per adjustment basis. Please further revise your presentation to separately present each adjustment in the reconciliation of Basic and Diluted Adjusted Net Income (Loss) per share. You may contact Jennifer O'Brien at 202-551-3721 or Ethan Horowitz at 202-551-3311 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
February 16, 2023
Michael S. Helm
Chief Financial Officer and Chief Accounting Officer
Berry Corporation (bry)
16000 Dallas Parkway, Suite 500
Dallas, Texas 75248
Re:Berry Corporation (bry)
Form 10-K for Fiscal Year Ended December 31, 2021
Response dated January 13, 2023
File No. 001-38606
Dear Michael S. Helm:
We have reviewed your January 13, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 14, 2022 letter.
Form 10-K for Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
How We Plan and Evaluate Operations
Operating Expenses, page 70
1.We have considered your responses to comment 1 in our letter dated November 4, 2022
and comment 1 in our letter dated December 14, 2022. However, we do not believe that
the presentation of the measure Operating Expenses, or the alternatively titled measure
and presentation you have proposed, is appropriate. Please revise your presentation as
necessary.
Non-GAAP Financial Measures, page 91
2.We note from your response to prior comment 3 that your reconciliations of Basic and
FirstName LastNameMichael S. Helm
Comapany NameBerry Corporation (bry)
February 16, 2023 Page 2
FirstName LastName
Michael S. Helm
Berry Corporation (bry)
February 16, 2023
Page 2
Diluted EPS on Adjusted Net Income (Loss) per share will not be provided on a per
adjustment basis. Please further revise your presentation to separately present each
adjustment in the reconciliation of Basic and Diluted Adjusted Net Income (Loss) per
share.
You may contact Jennifer O'Brien at 202-551-3721 or Ethan Horowitz at 202-551-3311
with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation