SEC Comment Letter for Frontdoor, Inc. (FTDR) (CIK 0001727263) (FTDR) — Apr 10, 2018
Frontdoor, Inc. (FTDR) (CIK 0001727263)
Date: April 10, 2018 · CIK: 0001727263 · Accession: 0000000000-18-010793
AI Filing Summary & Sentiment
Letter
April 10, 2018 Via E -mail Nikhel Varty, Chief Executive Officer American Holding Company Inc. c/o ServiceMaster Global Holdings, Inc. 150 Peabody Place Memphis, TN 381 03
Re: American Holding Company, Inc. Amendment No. 1 to Draft Registration Statement on Form 10 -12B Submitted March 30, 2018 CIK No. File No. 0001727263
Dear Mr. Varty:
We have reviewed your amended draft registration statement and have the following comment. In our comment, we may ask you to provide us w ith information so we may better understand your disclosure.
Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If yo u do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this comment and your amended draft regis tration statement or filed registration statement, we may have additional comments.
Description of Our Capital Stock
Exclusive Forum, page 122
1. Please explain the reasons why management adopted the exclusive forum provision contained in your certificate of incorporation.
Nikhel Varty American Holding Company Inc. April 10, 2018 Page 2
You may contact Becky Chow at (202)551 -6524 or Kristi Marrone at (202)551 -3429 if you have questions regarding comments on the financial statements and related matters. Please contact Stacie Gorman at (202)551 -3585 or me at (202)551 -3215 with any other questions.
Sincerely,
/s/ Kim McManus
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April 10, 2018 Via E -mail Nikhel Varty, Chief Executive Officer American Holding Company Inc. c/o ServiceMaster Global Holdings, Inc. 150 Peabody Place Memphis, TN 381 03 Re: American Holding Company, Inc. Amendment No. 1 to Draft Registration Statement on Form 10 -12B Submitted March 30, 2018 CIK No. File No. 0001727263 Dear Mr. Varty: We have reviewed your amended draft registration statement and have the following comment. In our comment, we may ask you to provide us w ith information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If yo u do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment and your amended draft regis tration statement or filed registration statement, we may have additional comments. Description of Our Capital Stock Exclusive Forum, page 122 1. Please explain the reasons why management adopted the exclusive forum provision contained in your certificate of incorporation. Nikhel Varty American Holding Company Inc. April 10, 2018 Page 2 You may contact Becky Chow at (202)551 -6524 or Kristi Marrone at (202)551 -3429 if you have questions regarding comments on the financial statements and related matters. Please contact Stacie Gorman at (202)551 -3585 or me at (202)551 -3215 with any other questions. Sincerely, /s/ Kim McManus Kim McManus Senior Counsel Office of Real Estate and Commodities cc: Andrew R. Brownstein, Esq. ( via e -mail)