SEC Comment Letter 0000000000-23-011262 to Global Crossing Airlines Group Inc. (JETBF, JETMF) (CIK 0001846084) (JETBF)
Global Crossing Airlines Group Inc. (JETBF, JETMF) (CIK 0001846084)
Date: Oct. 16, 2023 · CIK: 0001846084 · Accession: 0000000000-23-011262
AI Filing Summary & Sentiment
File numbers found in text: 000-56409
Letter
United States securities and exchange commission logo October 16, 2023 Ryan Goepel Chief Financial Officer Global Crossing Airlines Group Inc. 4200 NW 36th Street Building 5A Miami International Airport Miami, Florida 33166 Re:Global Crossing Airlines Group Inc. Form 10-K for the Fiscal Year ended December 31, 2022 Filed March 10, 2023 File No. 000-56409 Dear Ryan Goepel: We have reviewed your October 10, 2023 response to our comment letter and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our October 5, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 24 1.We note that in response to prior comment 1, you propose to include within your disclosures a table showing revenue, block hours, and revenue per block hour for each of Charter and ACMI although without quantifying the extent to which changes in revenues are attributable to changes in prices and separately to changes in volumes.
Please further revise your proposed disclosures to address the following points:
•Remove the dollar signs where you disclose the number of block hours and include
FirstName LastNameRyan Goepel Comapany NameGlobal Crossing Airlines Group Inc. October 16, 2023 Page 2 FirstName LastName Ryan Goepel Global Crossing Airlines Group Inc. October 16, 2023 Page 2 dollar signs where you disclose revenue per block hour.
•Quantify the changes in revenues resulting from price variances and separately from volume variances and discuss the reasons for such changes. For example, based on the data provided in your table, it appears that you would be disclosing that 91% of the increase in Charter revenue for 2022 relates to increased volumes while 9% relates to increased pricing, and that 51% of the increase in ACMI revenue for 2022 relates to increased volumes while 49% relates to increased pricing.
•Provide a qualitative discussion and analysis as to the reasons why volumes and prices increased for each of these revenue streams for all periods presented.
Please contact John Cannarella, Staff Accountant, at (202) 551-3337 or Karl Hiller, Branch Chief, at (202) 551-3686 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Energy & Transportation
Show Raw Text
United States securities and exchange commission logo
October 16, 2023
Ryan Goepel
Chief Financial Officer
Global Crossing Airlines Group Inc.
4200 NW 36th Street
Building 5A
Miami International Airport
Miami, Florida 33166
Re:Global Crossing Airlines Group Inc.
Form 10-K for the Fiscal Year ended December 31, 2022
Filed March 10, 2023
File No. 000-56409
Dear Ryan Goepel:
We have reviewed your October 10, 2023 response to our comment letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in our October 5, 2023
letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 24
1.We note that in response to prior comment 1, you propose to include within your
disclosures a table showing revenue, block hours, and revenue per block hour for each of
Charter and ACMI although without quantifying the extent to which changes in revenues
are attributable to changes in prices and separately to changes in volumes.
Please further revise your proposed disclosures to address the following points:
•Remove the dollar signs where you disclose the number of block hours and include
FirstName LastNameRyan Goepel
Comapany NameGlobal Crossing Airlines Group Inc.
October 16, 2023 Page 2
FirstName LastName
Ryan Goepel
Global Crossing Airlines Group Inc.
October 16, 2023
Page 2
dollar signs where you disclose revenue per block hour.
•Quantify the changes in revenues resulting from price variances and separately from
volume variances and discuss the reasons for such changes. For example, based on
the data provided in your table, it appears that you would be disclosing that 91% of
the increase in Charter revenue for 2022 relates to increased volumes while 9%
relates to increased pricing, and that 51% of the increase in ACMI revenue for 2022
relates to increased volumes while 49% relates to increased pricing.
•Provide a qualitative discussion and analysis as to the reasons why volumes and
prices increased for each of these revenue streams for all periods presented.
Please contact John Cannarella, Staff Accountant, at (202) 551-3337 or Karl Hiller,
Branch Chief, at (202) 551-3686 if you have questions regarding comments on the financial
statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation