SEC Comment Letter 0000000000-23-005305 to Liberty Latin America Ltd. (LILA, LILAB, LILAK) (CIK 0001712184) (LILA)
Liberty Latin America Ltd. (LILA, LILAB, LILAK) (CIK 0001712184)
Date: May 18, 2023 · CIK: 0001712184 · Accession: 0000000000-23-005305
AI Filing Summary & Sentiment
File numbers found in text: 001-38335
Letter
United States securities and exchange commission logo May 18, 2023 Christopher Noyes Chief Financial Officer Liberty Latin America Ltd. 2 Church Street Hamilton, Bermuda HM 11 Re:Liberty Latin America Ltd. Form 10-K for the Year Ended December 31, 2022 Filed February 22, 2023 Form 8-K filed May 8. 2023 File No. 001-38335 Dear Christopher Noyes: We have reviewed your April 20, 2023 response to our comment letter and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 8-K filed May 8, 2023 Non-GAAP Reconciliations for Consolidated Leverage Ratios, page 29 1.Your response to prior comment 3 states that your Consolidated Leverage Ratios are calculated to maintain consistency with the calculations set forth in the debt covenants included in the credit facility and/or bond agreements of each of your borrowing groups. Explain to us whether your presentation of leverage ratios is consistent with the material covenants of these credit agreements (including the Company's stand-alone credit agreements, if any).
FirstName LastNameChristopher Noyes Comapany NameLiberty Latin America Ltd. May 18, 2023 Page 2 FirstName LastName Christopher Noyes Liberty Latin America Ltd. May 18, 2023 Page 2 You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert Littlepage, Accountant Branch Chief 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 cc: Brian Zook
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United States securities and exchange commission logo
May 18, 2023
Christopher Noyes
Chief Financial Officer
Liberty Latin America Ltd.
2 Church Street
Hamilton, Bermuda HM 11
Re:Liberty Latin America Ltd.
Form 10-K for the Year Ended December 31, 2022
Filed February 22, 2023
Form 8-K filed May 8. 2023
File No. 001-38335
Dear Christopher Noyes:
We have reviewed your April 20, 2023 response to our comment letter and have the
following comment. In our comment, we ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 8-K filed May 8, 2023
Non-GAAP Reconciliations for Consolidated Leverage Ratios, page 29
1.Your response to prior comment 3 states that your Consolidated Leverage Ratios are
calculated to maintain consistency with the calculations set forth in the debt covenants
included in the credit facility and/or bond agreements of each of your borrowing groups.
Explain to us whether your presentation of leverage ratios is consistent with the material
covenants of these credit agreements (including the Company's stand-alone credit
agreements, if any).
FirstName LastNameChristopher Noyes
Comapany NameLiberty Latin America Ltd.
May 18, 2023 Page 2
FirstName LastName
Christopher Noyes
Liberty Latin America Ltd.
May 18, 2023
Page 2
You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief 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
cc: Brian Zook