SEC Comment Letter 0000000000-22-012978 to KLX Energy Services Holdings, Inc. (KLXE)
KLX Energy Services Holdings, Inc.
Date: Dec. 1, 2022 · CIK: 0001738827 · Accession: 0000000000-22-012978
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38609
Letter
United States securities and exchange commission logo December 1, 2022 Keefer M. Lehner Chief Financial Officer KLX Energy Services Holdings, Inc. 3040 Post Oak Boulevard 15th Floor Houston, TX 77056 Re:KLX Energy Services Holdings, Inc. Form 10-KT for the Year Ended December 31, 2021 Filed March 14, 2022 Form 8-K filed November 9, 2022 File No. 001-38609 Dear Keefer M. Lehner: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the Year Ended December 31, 2021 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 55 1.Please expand your discussion to include an analysis of your operating results for each of your reportable segments. When describing the changes in your results of operations on both a consolidated and segment basis, specifically identify and quantify the key drivers contributing the material changes in each period. Refer to Item 303 of Regulation S-K and SEC Release No. 33-8350.
FirstName LastNameKeefer M. Lehner Comapany NameKLX Energy Services Holdings, Inc. December 1, 2022 Page 2 FirstName LastName Keefer M. Lehner KLX Energy Services Holdings, Inc. December 1, 2022 Page 2 Form 8-K filed November 9, 2022 Exhibit 99.1 Non-GAAP Financial Measures, page 10 2.We note you present Adjusted EBITDA margin on a consolidated and segment basis. Please present the most directly comparable GAAP margin with equal or greater prominence to comply with Item 10(e)(1)(i)(A) of Regulation S-K. Refer to Question 102.10 of the Compliance and Disclosure Interpretations for Non-GAAP Measures.
In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Myra Moosariparambil, Staff Accountant, at (202) 551-3796 or Craig Arakawa, Branch Chief, at (202) 551-3650 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
December 1, 2022
Keefer M. Lehner
Chief Financial Officer
KLX Energy Services Holdings, Inc.
3040 Post Oak Boulevard
15th Floor
Houston, TX 77056
Re:KLX Energy Services Holdings, Inc.
Form 10-KT for the Year Ended December 31, 2021
Filed March 14, 2022
Form 8-K filed November 9, 2022
File No. 001-38609
Dear Keefer M. Lehner:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 55
1.Please expand your discussion to include an analysis of your operating results for each of
your reportable segments. When describing the changes in your results of operations on
both a consolidated and segment basis, specifically identify and quantify the key drivers
contributing the material changes in each period. Refer to Item 303 of Regulation S-K
and SEC Release No. 33-8350.
FirstName LastNameKeefer M. Lehner
Comapany NameKLX Energy Services Holdings, Inc.
December 1, 2022 Page 2
FirstName LastName
Keefer M. Lehner
KLX Energy Services Holdings, Inc.
December 1, 2022
Page 2
Form 8-K filed November 9, 2022
Exhibit 99.1
Non-GAAP Financial Measures, page 10
2.We note you present Adjusted EBITDA margin on a consolidated and segment basis.
Please present the most directly comparable GAAP margin with equal or greater
prominence to comply with Item 10(e)(1)(i)(A) of Regulation S-K. Refer to Question
102.10 of the Compliance and Disclosure Interpretations for Non-GAAP Measures.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Myra Moosariparambil, Staff Accountant, at (202) 551-3796 or Craig
Arakawa, Branch Chief, at (202) 551-3650 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation