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May 22, 2024
Robert Giammatteo
Chief Financial Officer
ARKO Corp.
8565 Magellan Parkway, Suite 400
Richmond, Virginia 23227
Re:ARKO Corp.
Form 10-K for Fiscal Year Ended December 31, 2023
Form 8-K furnished February 27, 2024
File No. 001-39828
Dear Robert Giammatteo:
            We have reviewed your filing and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis
Segment Results, page 29
1.Please tell us why the amounts disclosed in your tabular presentation of your results for
your acquisitions for the year ended December 31, 2023 do not agree with the amounts
disclosed when discussing the reasons for your period over period change.  As an
example, your retail fuel and merchandise revenue from acquisitions in your tabular
presentation on page 29 exceeds the amounts presented in your discussion of year over
year results on page 30. Please advise.
Use of Non-GAAP Measures, page 34
2.We note the following in regards to your presentation and reconciliation of your non-
GAAP measure of "Adjusted EBITDA":
•Please tell us how you concluded that excluding “Non-cash rent expense” does not
represent a tailored accounting principle. Refer to Question 100.04 of the staff's
Compliance and Disclosure Interpretation on non-GAAP financial measures.

 FirstName LastNameRobert Giammatteo
 Comapany NameARKO Corp.
 May 22, 2024 Page 2
 FirstName LastName
Robert Giammatteo
ARKO Corp.
May 22, 2024
Page 2
•In the footnote to your acquisition costs adjustment, you state the amount eliminates
"salaries of employees whose primary job function is to execute our acquisition
strategy and facilitate integration of acquired operations." It would appear these costs
would be normal, recurring, cash operating expenses necessary to operate your
business. Please tell us your consideration of Question 100.01 of the staff's
Compliance and Disclosure Interpretation on non-GAAP financial measures.
Item 8. Financial Statements
Consolidated Statements of Operations, page F-4
3.We note from your disclosure on page F-13 that fuel excise taxes are presented on a gross
basis and appear to represent approximately 12.5% of your total revenues.  Please tell us
your consideration of presenting fuel excise taxes on the face of your consolidated
statements of operations. Refer to Rule 5-03(1)(a) of Regulation S-X.
23. Segment Reporting, page F-51
4.We note you present total revenues from segments for each individual segment.  The
segment revenue measures present a revenue measure which differs from your revenues
from external customers calculated in accordance with GAAP. Please tell us your
consideration of ASC 280-10-50-22 in providing these segment measures.
5.It would appear your total revenues from segments and net income from segments
presented on a consolidated basis would be reflective of non-GAAP measures presented in
the notes to your financial statements. Refer to Item 10(e)(1)(ii)(C) of Regulation S-K.
Please advise.
Form 8-K furnished February 27, 2024
Exhibit 99.1, page 1
6.In the highlights of your earnings release you provide enhanced discussion regarding
periodic impacts to your non-GAAP measure of Adjusted EBITDA without providing
similar discussion when presenting the comparable GAAP measure. When presenting and
discussing non-GAAP measures, please ensure the comparable GAAP measures are
presented and discussed with equal or greater prominence. Refer to
Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the non-GAAP C&DI’s.

 FirstName LastNameRobert Giammatteo
 Comapany NameARKO Corp.
 May 22, 2024 Page 3
 FirstName LastName
Robert Giammatteo
ARKO Corp.
May 22, 2024
Page 3
            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.
            Please contact Abe Friedman at 202-551-8298 or Theresa Brillant at 202-551-3307 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services