Segment Reporting (ASC 280)

Company response: We respectfully submit below the response of Lionsgate Studios Corp., a British Columbia, Canada corporation (“Lionsgate,” the “Company,” “we,” “us,” or “our”), to the comment from the United States Securities and Exchange Commission staff (the “Staff”) regarding our Annual Report on Form 10-K for fiscal year ended March 31, 2026 contained in your letter dated July 21, 2026. For your convenience, we have included your original comments below in italics, immediately followed by our response. Form 10-K for Fiscal Year Ended March 31, 2026 Management's Discussion and Analysis of Financial Condition and Results of Operations Segment Results of Operations and Non-GAAP Measures, page 52 Comment 1… response letter →

Company response: ASU 2023-07 updates ASC 280-10-50 and states that all public entities, including those public entities that have a single reportable segment, shall disclose certain information for which an income statement is presented including: ● Factors used to identify the public entity’s reportable segments, including the basis of organization, ● Types of products and services, and ● The title and position of the individual identified as the chief operating decision maker. Management views the Company as a single segment and has included the following in its quarterly filings on Form 10-Q. This was inadvertently not included in our Form 10-K. The following will be included in Note 1 of the Notes to… response letter →

Company response: The Fund will make the requested change in future reports. Please call me (202-636-5806) with any questions you may have regarding this filing or if you wish to discuss the above responses. response letter →

Company response: We acknowledge the Staff’s comment, and confirm that, in future filings, the Company will quantify all factors that we believe materially impact changes in financial statement line items and are reasonably practicable to quantify. We also confirm that disclosures based on that standard will be provided for each significant income statement line item, as outlined in the example disclosure below, as well as for the segment discussion. In certain instances, the Company refers to factors that are not reasonably practicable to quantify. In some cases, but not all, multiple interrelated factors—such as pricing, volume, and mix—cannot be response letter →

Company response: The Company acknowledges the Staff’s comment regarding the requirements in ASC 280-10-50-30(b) as well as regarding the appearance of creating a non-GAAP measure of consolidated “other segment items”. In future filings, we will revise the presentation to remove such amount. Additionally, the disclosure of reportable segment operating income will be revised in future filings to include a reconciliation of the subtotal of segment operating income to consolidated income before income taxes. Please see the below as an example of how the Company would revise future filings based on the disclosure in Note 18 of the 2025 Form 10-K. Form 8-K furnished February 12, 2026 Exhibit 99.1, Earnings… response letter →

Company response: The Company acknowledges the Staff’s comment and confirms that the Company has considered the guidance in Question 100.01 of the Corporation Finance Interpretations on Non-GAAP Financial Measures. The Company confirms that the adjustment for these costs are not part of normal operations, as discussed below, and that the Company believes that the Company’s presentation of diluted earnings per share from continuing operations before charges/gains and operating income and margin before charges/gains shown is appropriate under the circumstances to give investors a representation of normal operating performance and period-to-period comparability. The items included as adjustments within “other… response letter →

Company response: The Company acknowledges the Staff’s comment. In future earnings releases, we will remove the reconciliation of Corporate Expense (GAAP) to General and Administrative expenses before charges/gains from our Operating Income reconciliation. ******** Should you or any member of the Staff have any additional questions or comments regarding our response or the applicable filing, please feel free to contact me at 440-962-2566, or, in my absence, Hiranda Donoghue, Executive Vice President, Chief Legal Officer and Corporate Secretary. response letter →

Company response: The Company respectfully advises the Staff that it carefully considered the disclosure requirements of ASC 280-10-50-22, 50-25, 50-26 and 50-30(c) in preparing the segment disclosures in Note 20 of the Form 10-K. As described below, the Company concluded that disclosure of total assets by reportable segment was not required because asset information is not included in the financial information regularly provided to the Company’s chief operating decision maker (“CODM”) for purposes of assessing segment performance or making resource allocation decisions. ​ ​ 4747 Bethesda Avenue, Suite 200, Bethesda, Maryland 20814 240.333.3600 jbgsmith.com ​ As disclosed in Note 20 of the Form 10-K, the… response letter →

Company response: The Company acknowledges the Staff’s comment regarding the presentation of segment expense disclosures and the distinction between significant expense categories under ASC 280-10-50-26A and other segment items under ASC 280-10-50-26B. The Company’s Chief Operating Decision Maker (“ CODM ”), identified as the Chief Executive Officer, evaluates segment performance primarily based on operating profit, and is regularly provided with certain expense information, including cost of revenue, selling, general and administrative expenses, depreciation and amortization, impairments of goodwill and long-lived assets, and gain/loss on sales of fixed assets. These expense measures reflect the primary… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment regarding the level of revenue disaggregation. The Company’s current disclosures include revenues from external customers and intersegment revenues for each reportable segment in accordance with ASC 280-10-50-22, as well as revenues by geographic area in accordance with ASC 280-10-50-41. The Company also considered the requirements of ASC 280-10-50-40, which requires disclosure of revenues for each product and service, or each group of similar products and services. In applying this guidance, the Company evaluated whether its product and service offerings represent distinct groupings with materially different characteristics and also… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment. We understand that Return on Invested Capital (ROIC) and Adjusted EBITDA are non-GAAP financial measures and, as such, are subject to the requirements of Regulation G and Item 10(e)(1)(i)(A) of Regulation S-K. In particular, we recognize that the most directly comparable GAAP measures must be presented with equal or greater prominence than the corresponding non-GAAP measures, as clarified in Question 102.10 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations. We confirm that, in future filings, we will update the Supplemental Information to present the most comparable GAAP measures with equal or greater… response letter →

Company response: In response to the Staff’s comment, the Company will revise its segment and geographic data disclosure to include the following statement beginning with its Form 10-Q for the first quarter of 2026: The Company’s CODM uses operating income and net income to monitor actual results against forecast and budget to identify business trends, assess operating performance, and modify capital allocation as necessary. The Company acknowledges that it and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, actions or absence of action by the Staff. Please do not hesitate to contact us with any questions or comments you may have. response letter →

Company response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that management has considered the impact of changes in its business and related end markets, including demand associated with generative AI and the electrification of transportation and infrastructure, in its determination of operating segments and related disclosures. As disclosed in Note 16 to the Company’s fiscal 2025 Annual Report on Form 10-K and Note 13 to the Company’s Quarterly Report on Form 10-Q for the quarter ended November 28, 2025, the Company has concluded that it operates as a single operating and reportable segment. The Company’s Chief Operating Decision Maker (“CODM”) reviews financial… response letter →

Company response: The Company respectfully advises the Staff that the acquisition of Incal Technology did not change the Company’s conclusion that it has one operating segment and one reportable segment. The acquisition of Incal Technology added complementary products that allow the Company to offer a broader range of testing products for both wafer-level and packaged-part burn-in applications. Following the acquisition, Incal’s operations were integrated into the Company’s existing organizational structure, including manufacturing, finance, sales, research and development, and other administrative functions. Consistent with that integration, the Company relocated Incal employees to Aehr’s principal Fremont… response letter →

Company response: to prior comment 2, including your proposed reconciliation of segment assets to consolidated assets. Please tell us how you determined the line currently titled “Corporate assets” contains no significant items that should be separately identified and described. For example, it appears almost half of “Corporate assets” may consist of goodwill not allocated to segments, and other acquired intangible assets not allocated to segments may represent a significant portion of the remainder. See ASC 280-10-50-31 and 280-10-55-49 for guidance. Company Response In future filings, we will present the reconciliation from segment assets to consolidated asset totals in more detail by including the… response letter →

Company response: 1. The Company respectfully acknowledges the Staff’s comment and undertakes to revise our future filings, beginning with its Annual Report on Form 10-K for the year ending March 31, 2026, to enhance and expand its accounting policy disclosures related to goodwill and indefinite-lived intangible asset impairment in Note 2 to its Consolidated Financial Statements and within the Critical Accounting Estimates discussion within Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”). For example, in any period that goodwill is impaired and considered a non-recurring fair value measurement, the Company will include the applicable ASC 820 disclosures, such as… response letter →

Company response: The disclosure referenced on page 37 that states, "We generally sell our products on a spot basis and as such, were exposed to sales prices on our products that decreased faster than the cost of the related raw materials" was intended 1 to convey an aggregated trend at the consolidated level and is reflected in the consolidated net sales and cost of sales explanations, on pages 40 and 41, where we disclose that "Net sales for fiscal 2025 decreased. . .primarily attributed to decreased average selling prices of $381.8 million" and "Cost of sales increased $50.1 million. . .the increase. . .was partially offset by lower input costs of $10.1 million." As the segment discussions are using… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that future annual reports on Form 20-F, including our Annual Report on Form 20-F for the fiscal year ending September 30, 2026, will disclose how the CODM uses operating results on a consolidated net income basis to measure segment performance and how to allocate resources. For the Staff’s reference, below is a markup of the relevant language we expect to include in our future filings (with this language reflecting what would have been included in the Annual Report): Segment Information and Revenue from Significant Customers The Company manages its operations as one operating segment, providing software products and… response letter →

Company response: The Company acknowledges the Staff’s comment. The negative selling, general and administrative (“SG&A”) amount for the Advanced Solutions segment for the three months ended December 28, 2024 primarily reflects income recognized during that period, including gains and reimbursements associated with the cessation of business as a result of the cancellation of a prior project, previously referred to as Project W (the "Project"). This was previously disclosed in Note 17: Cessation of Business in the Company's Annual Report on Form 10-K for the fiscal year ended October 4, 2025. In response to the Staff’s comment, the Company will revise its future filings to include an explanatory note to the… response letter →

Company response: The Company considered the requirements of Item 303(b) of Regulation S-K in preparing its MD&A for the quarterly period ended January 3, 2026, including whether to separately discuss changes in segment income from operations, which is the primary segment profitability measure reviewed by the Chief Operating Decision Maker (“CODM”) and disclosed in Note 15 to the consolidated condensed financial statements. As disclosed in Note 15, the CODM evaluates performance and allocates resources primarily based on income from operations, and the CODM is regularly provided with segment-level revenue, cost of sales, selling, general and administrative (“SG&A”) expense, and research and development… response letter →

Company response: We will revise our disclosure in our future filings to include how the CODM utilizes operating income as described below: The CODM uses the metrics outlined in the table below, along with internal management reports, to evaluate performance, monitor actual results versus budget and prior year results, and make strategic and operational resource allocation decisions. Please contact me response letter →

Company response: letter, specifically your response to comment four. You state that you disaggregate your revenue based on type of good or service (e.g., manufacturing and license fees) and regulatory pathway (e.g., ANDA vs NDA). Please address the following: ● Given that you have paused further development of NDAs and do not appear to have engaged in business activities in this segment since 2021, explain to us how disaggregation by regulatory pathway provides a meaningful level of disaggregation of your revenues. U.S. Securities and Exchange Commission ● In your February 20, 2024 response to prior comment four, you stated that when determining the level of revenue disaggregation, you considered the… response letter →

Company response: The Company acknowledges the Staff’s comment and clarifies that the Chief Operating Decision Maker (“CODM”) regularly reviews Consolidated Income from Operations as the measure of segment profit or loss, which is reported in the Company’s Consolidated Statements of Operations. The Company notes that the presentation of Operating Income by Segment in Note 14 did not clearly reconcile to the Consolidated Statements of Operations. The Company will include Income (Loss) from Operations as a line item within the segment results table to facilitate reconciliation in future filings as follows: For the Years Ended March 31, 2025 2024 Operating income by segment $ 32,121,818 $ 19,473,752 Corporate… response letter →

Company response: The Company acknowledges the Staff’s comment and confirms there are no significant segment expenses or other segment items that are separately provided to the CODM beyond research and development and general and administrative expenses. The CODM does not receive segment-level information related to depreciation, amortization, capital expenditures, or other non-cash items, and therefore such items are excluded. Going forward, the Company will enhance its segment disclosures to explicitly address the requirements of ASC 280-10-50-26A through 50-26C, including clarifying that significant segment expenses are presented in the Consolidated Statements of Operations and that no additional… response letter →

Company response: The Company will provide the requested reconciliations for adjusted OIBDA on a segment basis in its periodic reports on Form 10-K and Form 10-Q in future filings. The reconciliations for each of the Recorded Music and Music Publishing segments and Corporate for the fiscal years ended September 30, 2025, 2024 and 2023 and for the three months ended December 31, 2025 and 2024 are presented in the table below. Three Months Ended December 31, Fiscal Year Ended September 30, 2025 2024 2025 2024 2023 Recorded Music Recorded Music operating income 329 238 850 916 875 Depreciation and amortization expense 46 45 189 179 205 Restructuring and impairments 22 28 198 166 40 Executive transition costs —… response letter →

Company response: The Company will revise its segment footnote disclosure in future periodic reports on Form 10-K and Form 10-Q as set forth below. Corporate Recorded Music expenses and Music Publishing eliminations Total (in millions) September 30, 2025 Revenues 5,408 1,306 (7 ) 6,707 Cost of revenue 2,818 821 (7 ) 3,632 Selling and marketing expense 615 3 24 642 Distribution expense 112 — — 112 General and administrative expense 679 131 325 1,135 Restructuring & Impairment 198 5 31 234 Amortization expense 136 122 — 258 Operating income (loss) 850 224 (380 ) 694 Interest expense, net 162 Other expense, net 42 Income before income taxes 490 Total assets 5,328 3,463 1,038 9,829 Capital expenditures 22 3 114… response letter →

Company response: We acknowledge your comment regarding our compliance with the disclosure requirements of ASC 280-10-50-26A through 26C as it relates Note 4 – Segment Reporting. The CODM does not review disaggregated segment-level expenses beyond the amounts disclosed, but does review significant expenses at the consolidated level. The CODM delegates to segment leaders and function executives the responsibility of managing expenses. The Company will revise future disclosures to state the CODM does review expenses on a consolidated basis consistent with the categories of expenses on the consolidated statement of operations. The revised footnote disclosure will provide visibility of the consolidated expenses… response letter →

Company response: The sales and supply functions of our Industrial Group and Water Treatment Group largely operate independently of one another. However, the Company is well-positioned to realize supply chain synergies by leveraging the aggregate purchasing power of both groups. For example, because of the large volumes of raw material purchased by the Company as a whole, both groups are able to participate in favorable supplier pricing arrangements. In most cases where the Water Treatment Group has purchased raw materials in bulk, the purchases have been made directly by the Water Treatment Group at the same negotiated prices enjoyed by the Industrial Group. There are situations in which the Industrial… response letter →

Company response: The Company acknowledges the Staff’s comment and hereby confirms to the Staff that it will include in future periodic reports a qualitative and quantitative discussion of orders and backlog similar in scope to the information included in the Company’s Q4 Fiscal Year 2025 earnings presentations. Johnson Controls, Inc. 5757 N Green Bay Ave, Milwaukee, WI 53209 Segment Analysis, page 35 response letter →

Company response: The Company acknowledges the Staff’s comment and hereby confirms that it will include in future periodic reports and disclosures revised disclosure and presentation of Segment EBIT and Segment EBITA that identifies Segment EBITA as non-GAAP and includes the disclosures required by Item 10(e)(1)(i) of Regulation S-K. The Company will also make corresponding revisions to its future earnings releases. Consolidated Financial Statements Note 18. Segment Information Geographic Areas, page 100 response letter →

Company response: The Company acknowledges the Staff’s comment and hereby advises the Staff that, other than the United States, no individual country contributed revenue that was material for the year ended September 30, 2025. In assessing materiality, the Company referenced the 10% tests provided in ASC 280-10-50-12. We acknowledge that the Company is responsible for the accuracy of its disclosures, that the Commission is not foreclosed from taking action with respect to its filing and that the Company may not use the staff comments as a defense in any proceeding. response letter →

Company response: , or explain to us why no revision is needed to comply with ASC 280. Company Response As noted in our footnote 10, Business Segment Information, we stated that Corporate is not a reportable segment, but it is included for reconciliation purposes. This is to help the reader reconcile our segment disclosures back to our consolidated statements of operations and balance sheets. In future filings, we will present the segment information in a different manner to reconcile to the consolidated totals, as outlined in Exhibit 1. response letter →

Company response: For ease of reference, we have restated the Staff’s comment before our response below. Form 10-K for the Year Ended September 30, 2025 Management’s Discussion and Analysis Results of Operations Definition of Terms and Non-GAAP Financial Measures, page 30 As noted on page 31, your non-GAAP measure, total segment EBIT, excludes unallocated corporate overhead expenses, such as certain corporate salaries and headquarters expenses, plus costs related to special projects and initiatives. As such, this non-GAAP measure appears to exclude normal, recurring, cash operating expenses and may therefore not comply with Rule 100(b) of Regulation G and Item 10(e) of Regulation S-K. With specific reference… response letter →

Company response: to prior comment two with a view toward ascertaining the extent to which Biopharmaceuticals and Exemplar continue to constitute two separate operating segments as defined in ASC 280-10-50-1: · Regarding the second bullet, you have told us that you have two separate components or reporting units that were not aggregated under ASC 350-20-35-33 through 35-36. You also appear to indicate that your chief operating decision maker (CODM) continues to receive at least some level of separate discrete financial information for these reporting units. Please tell us what financial information is received by the CODM, and how it changed in the first quarter of 2025 and subsequent periods. · Clarify how… response letter →

Company response: to prior comment 1. Please further revise to discuss how the CODM uses the segment measure of profitability in assessing segment performance and deciding how to allocate resources. Refer to ASC 280-10-50-29(f) and the example in ASC 280-10-55-54(c). Response : The Company acknowledges the Staff’s comment. The Company proposes to further revise Note 2 (Segment Reporting) to explain how the Chief Executive Officer, as the chief operating decision maker (“CODM”), uses the segment measure of profitability (net income) in assessing performance and in deciding how to allocate resources, consistent with ASC 280-10-50-29(f) and ASC 280-10-55-54(c). Segment Reporting ASC 280, Segment Reporting,… response letter →

Company response: We respectfully acknowledge the Staff’s comment and will remove totals for both adjusted cost of sales and adjusted operating expenses from the operating segment note to the financial statements in future filings. The Company is committed to serving its investors with accurate and understandable disclosures regarding its operations and financial condition. We appreciate the efforts of the Commission to assist us with that goal. response letter →

Company response: We respectfully acknowledge the Staff’s comment and will enhance our disclosure prospectively, beginning with our Form 10-Q for the quarter ended January 31, 2026 as follows (the use of italics indicates existing disclosures and the use of bold indicates additions): The CODM uses operating income, as presented in our financial reports, as the primary measure of segment profitability to assess the performance of the segments and make decisions on resource allocation across segments. The CODM evaluates segment operating income on a quarterly basis by comparing actual results to forecasted amounts and historical performance. These evaluations, supported by discussions with the leadership team… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment. In future filings, beginning with the Company’s Form 10-K for the year ending February 28, 2026, we will expand our disclosures in Management’s Discussion and Analysis of Financial Condition and Results of Operations to include information substantially similar to the following (example based on amounts from the 10-Q for the fiscal quarter ended November 30, 2025): Sales for the AZZ Metal Coatings segment increased $26.4 million, or 15.7%, for the current quarter, compared to the prior year quarter. The increase was primarily due to $30.0 million resulting from a higher volume of steel processed, primarily due to increases in the… response letter →

Company response: 7 . In future filings, the Registrant will revise the disclosure to specify that the Registrant’s chief operating decision maker is the Adviser’s Executive Committee (comprising the CEO, CFO, General Counsel and COO), which regularly evaluates performance and resource allocation decisions for the Registrant. response letter →

Company response: The Company confirms that management considered Rule 5-03(b) of Regulation S-X and the guidance under ASC-606-10-50-5, ASC 606-10-55-89 through 55-91 and ASC 280-10-50-40 in evaluating the Company’s presentation of revenue and costs of revenue. In evaluating the presentation of revenues and costs of revenues under Rule 5-03(b) of Regulation S-X, management considered whether the Company’s revenues from products, services, and other activities warrant separate presentation on the face of the consolidated statements of operations. Rule 5-03(b) of Regulation S-X provides that “ if income is derived from more than one of the sub-captions described under § 210.5-03.1, each class which is not… response letter →

Company response: to prior comment 2 appears to indicate that your CODM utilizes "adjusted" operating income (loss), rather than operating income (loss), to evaluate income generated from segment resources. Please confirm that you will accurately name and describe the measures CODM utilizes to evaluate income generated from segment resources in your future filings. Company Response : We respectfully acknowledge the Staff’s comment and confirm that the CODM utilizes operating income (loss) to evaluate income generated from segment resources. In future filings, the Company confirms that it will accurately name and describe the measures the CODM utilizes to evaluate income generated from segment resources. * *… response letter →

Company response: We respectfully acknowledge the Staff’s comment and provide the following information in response. For your convenience, each bullet of the Staff’s comment is reproduced in italicized type below, followed by our responses thereto: • Tell us and revise your future filings to clarify whether Biopharmaceuticals and Exemplar remain separate reporting units. The Company respectfully acknowledges the Staff's comment and advises the Staff that Biopharmaceuticals and Exemplar remain separate reporting units for purposes of ASC 350-20. We also advise the Staff that as of December 31, 2025, there was no intangible assets nor goodwill associated with the Exemplar reporting unit subsequent to an… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and explains that while segment Gross profit (loss) is included in the financial information that is provided to the CODM for informational purposes, the CODM does not use segment Gross profit (loss) when assessing performance and allocating resources. The CODM uses the segment Operating income (loss) to allocate resources and assess performance. Therefore, the Company believes it is the metric required to be disclosed under the guidance in ASC 280-10-50-28A. In future filings, the Company plans to present only this required measure. To address the Staff’s comment and limit confusion on the metric used by the CODM in future filings,… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that the only segment expense information regularly provided to the CODM is segment Selling, general and administrative expenses. However, as both segment Net sales and segment Gross profit (loss) are also regularly provided to the CODM, segment Cost of sales is significant and easily computable from information regularly provided to the CODM. In future filings, the Company will include disclosure of segment Cost of sales in accordance with the guidance in ASC 280-10-50-26A and 55-15B. Please see the response to Comment 4 below for an illustrative example of future planned disclosures. Further, in accordance with… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms, as discussed above, that the only measure of segment profit/loss used by the CODM to assess performance and allocate resources is segment Operating income (loss). In future filings, beginning with the Form 10-K for the fiscal year ended December 31, 2025, the Company will update its segment disclosures and proposes to include a reconciliation of segment Operating income (loss) to consolidated Earnings (loss) before income taxes in accordance with ASC 280-10-50-28C and 50-30(b). For illustrative purposes, the following is an example of the updated segment disclosure using amounts for the year ended December 31, 2024 ($… response letter →

Company response: In future filings, the Fund will identify a more specific group within the Manager, or an individual, as the CODM. response letter →

Company response: The Fund will make the requested change in a future filing. response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that in future filings it will revise the table summarizing consolidated net sales and adjusted EBITDA by segment to remove the line item for “unallocated corporate expenses” and the subtotal “Adjusted EBITDA.” Please refer to Exhibit 1 for an example of the revised disclosure for the 2024 and 2023 fiscal years. Note 1. Description of the Business, Basis of Presentation and Summary of Significant Accounting Policies Non-GAAP Financial Measures, page 86 response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that in future filings it will remove from Note 1 the disclosure regarding Non-GAAP Financial Measures. Additionally, in future filings, the Company will remove the measure of total Adjusted EBITDA from the segment disclosure in Note 20. Please refer to Exhibit 2 for an example of the revised disclosure for the fiscal years ended January 3, 2025, December 29, 2023, and December 30, 2022. Note 20. Segment Information, page 112 response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that in future filings it will reconcile segment Adjusted EBITDA to consolidated income before income taxes and discontinued operations and include unallocated corporate expenses as a reconciling item below segment Adjusted EBITDA as required by ASC 280-10-50-30(b). Please refer to Exhibit 2 for an example of the revised disclosure for the fiscal years ended January 3, 2025, December 29, 2023, and December 30, 2022. 2 Squire Patton Boggs (US) LLP response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that in future filings the Company will remove the line item for unallocated corporate expenses and the total for the amounts of other segment items. In addition, in future filings, the Company will revise and expand its disclosure in Note 20 to state that the chief operating decision maker reviews expenses on a consolidated basis and that no segment level expense information is regularly provided to the chief operating decision maker. The Company will also relocate from Note 1 to Note 20 its existing disclosure that describes how the chief operating decision maker uses segment Adjusted EBITDA to assess segment… response letter →

Company response: The Company proposes to revise Footnote 2 (Segment Reporting) in future filings to include the following disclosure: Segment Reporting ASC 280, Segment Reporting, establishes standards for reporting information about operating segments based on the manner in which management organizes the business and evaluates financial performance. Operating segments are components of an enterprise for which discrete financial information is available and regularly reviewed by the chief operating decision maker (“CODM”) to allocate resources and assess performance. The Company has identified its Chief Executive Officer as the CODM. The CODM reviews the Company’s results only on a consolidated basis and… response letter →