CORRESP Filing
Frontdoor, Inc.
Date: April 15, 2025 · CIK: 0001727263 · Accession: 0000950170-25-054366
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38617
Referenced dates: April 2, 2025
Letter
Jessica P. Ross Senior Vice President and Chief Financial Officer April 15, 2025 VIA EDGAR Division of Corporation Finance Office of Real Estate & Construction Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Valeria Franks and Keira Nakada Re: Frontdoor, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Item 2.02 Form 8-K filed February 27, 2025 File No. 001-38617 Dear Ms. Franks and Ms. Nakada: Frontdoor, Inc. (the “Company,” “we” or “our”) is submitting the following response to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission dated April 2, 2025, regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2024 and Current Report on Form 8-K filed on February 27, 2025 in accordance with the Securities Exchange Act of 1934, as amended. To assist your review, we have retyped the text of the Staff’s comment in italics below. Item 2.02 Form 8-K filed February 27, 2025 Exhibit 99.1 Fourth-Quarter 2024 Results, page 2 1. When you present and/or discuss a non-GAAP measure in your earnings release, please also present and/or discuss the comparable GAAP measure in the same manner. For example, when you disclose period-over-period adjusted EBITDA bridge, also disclose period-over-period net income bridge. The narrative section analysis below the bridge also has similar issues to those described above. Refer to Question 102.10(a) of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations and Item 10(e)(1)(i) of Regulation S-K. The Company respectfully acknowledges the Staff’s comment and will revise its presentation and discussion of non-GAAP measures in future filings (including earnings releases furnished on Form 8-K) to present and discuss the comparable GAAP measure in the same manner.
Please do not hesitate to call me at (901) 422-9709 with any questions or further comments you may have or if you wish to discuss the above response. Very truly yours, FRONTDOOR, INC. By: /s/ Jessica P. Ross___________ Name: Jessica P. Ross Title: Senior Vice President and Chief Financial Officer cc: Frontdoor, Inc. Jeffrey A. Fiarman cc: Simpson Thacher & Bartlett LLP Kenneth B. Wallach
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CORRESP
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CORRESP
Jessica P. Ross Senior Vice President and Chief Financial Officer April 15, 2025 VIA EDGAR Division of Corporation Finance Office of Real Estate & Construction Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Attention: Valeria Franks and Keira Nakada Re: Frontdoor, Inc. Form 10-K for Fiscal Year Ended December 31, 2024 Item 2.02 Form 8-K filed February 27, 2025 File No. 001-38617 Dear Ms. Franks and Ms. Nakada: Frontdoor, Inc. (the “Company,” “we” or “our”) is submitting the following response to the comment letter of the staff (the “Staff”) of the Securities and Exchange Commission dated April 2, 2025, regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2024 and Current Report on Form 8-K filed on February 27, 2025 in accordance with the Securities Exchange Act of 1934, as amended. To assist your review, we have retyped the text of the Staff’s comment in italics below. Item 2.02 Form 8-K filed February 27, 2025 Exhibit 99.1 Fourth-Quarter 2024 Results, page 2 1. When you present and/or discuss a non-GAAP measure in your earnings release, please also present and/or discuss the comparable GAAP measure in the same manner. For example, when you disclose period-over-period adjusted EBITDA bridge, also disclose period-over-period net income bridge. The narrative section analysis below the bridge also has similar issues to those described above. Refer to Question 102.10(a) of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations and Item 10(e)(1)(i) of Regulation S-K. The Company respectfully acknowledges the Staff’s comment and will revise its presentation and discussion of non-GAAP measures in future filings (including earnings releases furnished on Form 8-K) to present and discuss the comparable GAAP measure in the same manner.
Please do not hesitate to call me at (901) 422-9709 with any questions or further comments you may have or if you wish to discuss the above response. Very truly yours, FRONTDOOR, INC. By: /s/ Jessica P. Ross___________ Name: Jessica P. Ross Title: Senior Vice President and Chief Financial Officer cc: Frontdoor, Inc. Jeffrey A. Fiarman cc: Simpson Thacher & Bartlett LLP Kenneth B. Wallach
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