November 12, 2021
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attn: | Mr. Ameen Hamady |
Ms. Shannon Menjivar
Re: | APi Group Corporation |
Form 10-K for the year ended December 31, 2020
Filed on March 24, 2021
Form 8-K filed on August 11, 2021
File No. 001-39275
Dear Mr. Hamady and Ms. Menjivar:
APi Group Corporation (the Company), hereby responds to the comment provided by the Staff (the Staff) of the Securities and Exchange Commission (the Commission) in its letter dated November 2, 2021 (the Comment Letter) regarding the Companys Form 10-K for the year ended December 31, 2020 (the 2020 Form 10-K) and the Companys Form 8-K filed on August 11, 2021. Set forth below in bold font is the comment of the Staff contained in the Comment Letter and immediately below the comment is the response of the Company with respect thereto.
Form 8-K filed on August 11, 2021
General
1. | We note your response to our comment. While it is noted that the step-up adjustment will no longer be necessary after September 30, 2021, due to the comparative nature of your non-GAAP presentations which include prior periods, it appears that such adjustment will continue to be presented in filings subsequent to your September 30, 2021 filings. Please remove this adjustment from all future filings including any filings reflecting comparative periods that previously included such an adjustment. |
The Company respectfully acknowledges the Staffs comment and appreciates the Staffs continued dialogue regarding the comment. In response to the Staffs comment, the Company agrees that it will not include the Depreciation remeasurement adjustment in any of its non-GAAP financial measures presented in any future filings and public disclosures, including those reflecting comparative periods that previously included this adjustment.
We hope that this response adequately addresses the Staffs concerns. If you have any further comments or concerns, please to contact me at (651) 604-2708.
Very truly yours, |
/s/ Kevin Krumm |
Kevin Krumm Chief Financial Officer |