SEC Comment Letter 0000000000-23-000200 to MYT Netherlands Parent B.V. (MYTE) (CIK 0001831907) (LUXE)
MYT Netherlands Parent B.V. (MYTE) (CIK 0001831907)
Date: Jan. 6, 2023 · CIK: 0001831907 · Accession: 0000000000-23-000200
AI Filing Summary & Sentiment
File numbers found in text: 001-39880
Letter
United States securities and exchange commission logo January 6, 2023 Michael Kliger Chief Executive Officer MYT Netherlands Parent B.V. Einsteinring 9 85609 Ascheim/Munich Germany Re:MYT Netherlands Parent B.V. Form 20-F for the Fiscal Year Ended June 30, 2022 Filed September 15, 2022 File No. 001-39880 Dear Michael Kliger: We have reviewed your filings 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 20-F for the Fiscal Year Ended June 30, 2022 Item 5. Operating and Financial Review and Prospects Non-IFRS Measures, page 68 1.We note that you present certain Non-IFRS measures on page 68 such as Adjusted EBITDA Margin, Adjusted Operating Income Margin, and Adjusted Net Income Margin but do not provide equally prominent disclosure of the most comparable IFRS measure as required by Item 10(e)(1)(i)(A) of Regulation S-K. Please revise to provide equally prominent disclosure of the most comparable IFRS measure for all of the Non-IFRS measures disclosed here and elsewhere in your filing such as in the last paragraph on page 54 where you discuss your Adjusted EBITDA margin and the first paragraph on page 58 where you discuss Adjusted Operating Income but not the most comparable IFRS measures.
FirstName LastNameMichael Kliger Comapany NameMYT Netherlands Parent B.V. January 6, 2023 Page 2 FirstName LastName Michael Kliger MYT Netherlands Parent B.V. January 6, 2023 Page 2
MYT Netherlands Parent B.V. Consolidated Financial Statements Notes to the Consolidated Financial Statements for the period ended 30 June 2022 13. Earnings per Share, page F-26 2.Please explain why the weighted average ordinary shares outstanding used to compute basic and diluted earnings per share for the fiscal year ended June 30, 2022 of 86.3 million shares exceeds the number of outstanding shares at the beginning and end of this period of 84.5 million and 84.7 million as disclosed in the table on page F-33. Please advise or revise. 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 Linda Cvrkel at (202)551-3813 or Angela Lumley at (202) 551-3398 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
Show Raw Text
United States securities and exchange commission logo
January 6, 2023
Michael Kliger
Chief Executive Officer
MYT Netherlands Parent B.V.
Einsteinring 9
85609 Ascheim/Munich
Germany
Re:MYT Netherlands Parent B.V.
Form 20-F for the Fiscal Year Ended June 30, 2022
Filed September 15, 2022
File No. 001-39880
Dear Michael Kliger:
We have reviewed your filings 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 20-F for the Fiscal Year Ended June 30, 2022
Item 5. Operating and Financial Review and Prospects
Non-IFRS Measures, page 68
1.We note that you present certain Non-IFRS measures on page 68 such as Adjusted
EBITDA Margin, Adjusted Operating Income Margin, and Adjusted Net Income Margin
but do not provide equally prominent disclosure of the most comparable IFRS measure as
required by Item 10(e)(1)(i)(A) of Regulation S-K. Please revise to provide equally
prominent disclosure of the most comparable IFRS measure for all of the Non-IFRS
measures disclosed here and elsewhere in your filing such as in the last paragraph on page
54 where you discuss your Adjusted EBITDA margin and the first paragraph on page 58
where you discuss Adjusted Operating Income but not the most comparable IFRS
measures.
FirstName LastNameMichael Kliger
Comapany NameMYT Netherlands Parent B.V.
January 6, 2023 Page 2
FirstName LastName
Michael Kliger
MYT Netherlands Parent B.V.
January 6, 2023
Page 2
MYT Netherlands Parent B.V. Consolidated Financial Statements
Notes to the Consolidated Financial Statements for the period ended 30 June 2022
13. Earnings per Share, page F-26
2.Please explain why the weighted average ordinary shares outstanding used to compute
basic and diluted earnings per share for the fiscal year ended June 30, 2022 of 86.3 million
shares exceeds the number of outstanding shares at the beginning and end of this period of
84.5 million and 84.7 million as disclosed in the table on page F-33. Please advise or
revise.
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 Linda Cvrkel at (202)551-3813 or Angela Lumley at (202) 551-3398
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services