0001193125-17-177553.txt : 20170620 0001193125-17-177553.hdr.sgml : 20170620 20170522111955 ACCESSION NUMBER: 0001193125-17-177553 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20170522 FILER: COMPANY DATA: COMPANY CONFORMED NAME: DDR CORP CENTRAL INDEX KEY: 0000894315 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 341723097 STATE OF INCORPORATION: OH FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 3300 ENTERPRISE PARKWAY CITY: BEACHWOOD STATE: OH ZIP: 44122 BUSINESS PHONE: 2167555500 MAIL ADDRESS: STREET 1: 3300 ENTERPRISE PARKWAY CITY: BEACHWOOD STATE: OH ZIP: 44122 FORMER COMPANY: FORMER CONFORMED NAME: DEVELOPERS DIVERSIFIED REALTY CORP DATE OF NAME CHANGE: 19940218 CORRESP 1 filename1.htm CORRESP

May 22, 2017

CORRESPONDENCE FILING VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

 

Attention:    Wilson K. Lee, Senior Staff Accountant
   Babette Cooper, Staff Accountant
     
   Re:    DDR Corp.
      Form 10-K for the Fiscal Year Ended December 31, 2016
      Filed February 21, 2017
      Form 8-K
      Filed February 14, 2017
      File No. 001-11690

Ladies and Gentlemen:

DDR Corp., an Ohio corporation (the “Company” or “we,” “us” or “our”), is submitting this letter in response to the follow up letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), dated May 10, 2017 (the “Comment Letter”), with respect to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2016, filed February 21, 2017 and the Form 8-K filed February 14, 2017 (the “Form 8-K”).

Below is the Company’s response. For the convenience of the Staff, the Company has repeated the Staff’s comment before the response.

Form 8-K filed February 14, 2017

Exhibit 99.1

 

  1. We have reviewed your response to comment one of our letter dated April 21, 2017 and have taken your analysis into consideration. We continue to believe that when you provide an operating metric on a pro-rata basis, it is also important to include a consolidated and unconsolidated equivalent on a stand-alone basis. Please revise your disclosures in future earnings supplements accordingly.

United States Securities and Exchange Commission

Division of Corporation Finance

Page 2

 

Response:

We will revise our disclosure of operating metrics provided on a pro-rata basis in the quarterly earnings supplement starting in the second quarter of 2017 to include for each such metric a consolidated and unconsolidated equivalent on a stand-alone basis.

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If you have any questions regarding these matters, please do not hesitate to contact the undersigned at 216-755-6400.

 

Very truly yours,
/s/ Matthew L. Ostrower

Matthew L. Ostrower

Executive Vice President,

Chief Financial Officer and Treasurer

 

cc: Christa A. Vesy, Executive Vice President
   and Chief Accounting Officer