Non-GAAP measures

The Company respectfully acknowledges the Staff’s comment and is furnishing a copy of the Updated Teamshares Presentation to the Commission as Exhibit 99.1 to the Amended Current Report on Form 8-K intended to be responsive to the Staff’s comment. Historical Financial Results and Reconciliation of Non-GAAP Measures, Page 81

The Company respectfully acknowledges the Staff’s comment and is furnishing a copy of the Updated Teamshares Presentation to the Commission as Exhibit 99.1 to the Amended Current Report. The Updated Teamshares Presentation has been revised to remove references to consolidated Operating EBITDA and associated amounts and measures the computation of which are based on or derived from such metric, including Pro Forma Operating EBITDA and Return on Equity . * * * 2 We thank you for your review of the foregoing and the Form 8-K/A and Exhibit 99.1. Should you have any questions or require any additional information, please do not hesitate to contact our legal counsel, Meredith Laitner, Esq., of Ellenoff Grossman & Schole LLP, at mlaitner@egsllp.com or by telephone at (212) 370-1300. Very truly yours, Live oak acquisition corp. v By: /s/ Richard J. Hendrix Name: Richard J. Hendrix Title:…

We acknowledge the Staff’s comment and confirm that in future filings, we will provide such reconciliations or, alternatively, if applicable, provide a statement that the information could not be presented without unreasonable efforts under Item 10(e)(1)(i)(B) of Regulation S-K, as applicable. If you have any questions, or require additional information or documents, please contact the undersigned. Very truly yours, SMARTSTOP SELF STORAGE REIT, INC. By: /s/ James R. Barry James R. Barry Chief Financial Officer and Treasurer Phone: (949) 542-4513 Direct Email: jbarry@smartstop.com) cc: H. Hirsch, Nelson Mullins Riley & Scarborough LLP N. Look, General Counsel and Secretary, SmartStop Self Storage REIT, Inc. Brent Horak, BDO USA, P.C. SmartStop Self Storage | 10 Terrace Road, Ladera Ranch, CA 92694 | 949.429.6600 | smartstop.com

The Company respectfully informs the Staff that in applicable future filings, it will revise its disclosures to present with equal or greater prominence Net Income (Loss) Attributable to Common Stockholders per Diluted Share, which is the most directly comparable measure calculated in accordance with GAAP. Set forth in Exhibit A hereto is a copy of the earnings release that was included as an exhibit to the Form 8-K, which has been marked to show the Company’s proposed revisions in response to the Staff’s comment (additions appear in bold underline and deletions in strikethrough font). * * * * * If you have any questions or comments with regard to these responses or other matters, or would like any additional information, please call the undersigned at (213) 891-7421. Sincerely, /s/ Steven B. Stokdyk Steven B. Stokdyk of LATHAM & WATKINS LLP cc: Aaron R. Reyes, Executive Vice President…

The Company confirms that it will present the most directly comparable GAAP financial measure with equal or greater prominence when presenting non-GAAP financial measures beginning with its press release announcing financial results for its fourth quarter and fiscal year ending March 29, 2026. Accordingly, to the extent future Company disclosure includes a presentation of Adjusted EBITDA, net income will be presented with equal or greater prominence. Please contact me at +1 (612) 331-6910 should there be any questions or additional comments with respect to the above responses. Yours truly, HAWKINS, INC. By: /s/ Jeffrey P. Oldenkamp Jeffrey P. Oldenkamp Executive Vice President and Chief Financial Officer cc: Patrick H. Hawkins, Chief Executive Officer and President Dan Louismet, Interim General Counsel and Secretary Steven C. Kennedy, Faegre Drinker Biddle & Reath LLP Joshua L. Colburn,…

In response to the Staff’s comment, the Company intends to include disclosure in its future applicable filings to include both the quantification and business reasons of the material changes in each Segment’s Adjusted EBIT for the periods presented in addition to the discussion of the material changes in each segment’s Adjusted EBITDA for such periods that is currently presented. The Company will also include quantification and the business reasons for material changes in periods in Total Corporate Expenses within Adjusted EBIT and Adjusted EBITDA.

In response to the Staff’s comment, the Company intends to include in its future applicable filings the disclosures required by Item 10(e) of Regulation S-K for each segment’s Adjusted EBITDA, including a reconciliation provided to Adjusted EBIT which is the measure presented in conformity with Accounting Standards Codification 280 required to be disclosed in accordance with GAAP. Consolidated Financial Statements Note 19 - Segment Reporting, page 104

The Company respectfully acknowledges the Staff’s comment. In future filings, the Company will revise its disclosures to further discuss the reasons why it believes that presentation of its non-GAAP financial measures provides useful information to investors and will describe each of the adjusting items in accordance with paragraph (e)(1)(i)(C) of Item 10 of Regulation S-K. The Company’s revised disclosure will read as follows: “Non-GAAP Financial Measures As a supplement to our financial measures presented in accordance with U.S. Generally Accepted Accounting Principles (“GAAP”), the Company presents certain adjusted (non-GAAP) measures of financial performance. These non-GAAP financial measures are not intended to be considered in isolation from, as a substitute for, or as more important than, the financial information prepared and presented in accordance with GAAP. In addition, these…

The Company respectfully acknowledges the Staff’s comment and has considered the guidance set forth in Question 100.01 of the Compliance and Disclosure Interpretations related to non-GAAP measures (“ C&DI 100.01 ”). The Company believes that making adjustments to exclude acquisition related compensation and benefits is appropriate and consistent with the guidance provided in C&DI 100.01 and further believes that such adjustments enhance the clarity and usefulness of the Company’s non-GAAP financial measures for its investors. Nature of the Company’s Acquisition Strategy As a professional services firm, the Company operates in a people-focused industry and is differentiated from its public peers in that it regularly uses acquisitions, in addition to organic hiring, as a way to grow its business. In executing acquisitions, the Company determines an overall purchase price (the “ Purchase…

We respectfully acknowledge the Staff’s comment and we advise that in future annual reports to security holders, we will include a table that reconciles any non-GAAP financial measure to its most directly comparable GAAP measure, including any reconciliations required in our Annual Report to Security Holders for Fiscal Year Ended February 1, 2026. By way of example, the following is a reconciliation of Adjusted Diluted EPS that was included in our earnings release furnished as part of the Current Report on Form 8-K, dated March 11, 2025. DULUTH HOLDINGS INC. Reconciliation of Net Loss to Adjusted Net Loss and Adjusted Net Loss to Adjusted EPS (Unaudited) Three Months Ended Twelve Months Ended February 2, 2025 February 2, 2025 (in thousands, except per share amounts) Amount Per share Amount Per share Net loss attributable to controlling interest $ (5,586 ) $ (0.17 ) $ (43,671 ) $ (1.31 )…

The “tax valuation allowance” adjustment represents a discrete, non-cash charge recorded to establish a valuation allowance against deferred tax assets. We record net deferred tax assets to the extent we believe these assets will more likely than not be realized. A valuation allowance is established if it is more likely than not that some portion or all of the deferred income tax asset will not be realized. The Company considers this a discrete adjustment rather than a reflection of the Company’s ongoing performance. It also does not preclude our business from utilizing the underlying tax credits for which the valuation allowance was established. Management believes excluding this discrete tax item is meaningful because it allows investors to evaluate the Company’s core results on a basis consistent with prior periods and provides better visibility into the underlying tax rate…

In response to this comment, commencing with our FY 2026 Form 10-K, we will move the sections entitled “Adjusted EBITDA” and “Non-GAAP net income,” which include a discussion of non-GAAP financial measures, from their current location to a new section to be captioned “Non-GAAP financial measures” that follows the “Results of operations” section, which contains a discussion of our GAAP results, so that our discussion and analysis of our GAAP measures have equal or greater prominence than our non-GAAP discussion. Our existing section titled “Key financial and operating metrics” will accordingly be renamed “Key operating metrics” to reflect the removal of these sections, as the sections “Adjusted EBITDA” and “Non-GAAP net income” were previously presented as subcategories under this heading. 2. We note that the reconciliation of net income to non-GAAP net income includes an adjustment for…

The Company acknowledges the Staff's comment and confirms that, in future filings, it will refer to this ratio as “Adjusted Return on Invested Capital” (Adjusted ROIC), and disclose what the measure is intended to represent and why the Company believes the measure provides useful information to investors. Additionally, we will explain the purpose and basis for all adjustments made in the calculation of Adjusted ROIC with footnote disclosure. We will also present the ratio using the most directly comparable GAAP measures and refer to it as “Return on Invested Capital” (ROIC). An example of the intended future disclosure of ROIC and Adjusted ROIC based on an illustrative revision of the actual disclosure in Exhibit 99.1 to the Company’s Form 8-K furnished on March 19, 2025 is presented below. Adjusted Return on Invested Capital (“Adjusted ROIC”) We believe that Adjusted ROIC is a useful…

The Company respectfully acknowledges the Staff’s comment. The Company will include the most directly comparable GAAP measure with equal or greater prominence in future filings, beginning with the Company’s Form 8-K for the 4 th quarter 2025 earnings release. If you have any questions regarding the foregoing, please do not hesitate to contact me at (773) 304-5665, or by email at ron.knutson@distributionsolutionsgroup.com. Very truly yours, /s/ Ronald J. Knutson Ronald J. Knutson Distribution Solutions Group, Inc. EVP and Chief Financial Officer cc: Richard Pufpaf Distribution Solutions Group, Inc. General Counsel Anna T. Pinedo Mayer Brown LLP

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

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

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 performance and allocate resources. Please refer to Exhibit 3 for an example of the revised table and revised disclosure. *** We hope that you will find the Company’s response to the Comment Letter…

We respectfully acknowledge the Staff’s comment. • Confirm that you will disclose prior year comparative information; We confirm that we have provided prior year comparative information related to adjusted diluted net loss per share for our most recently filed earnings release for the period ended September 30, 2025, furnished with the Commission on October 27, 2025 under Item 2.02 of our Current Report on Form 8-K (the “ Q3 2025 Earnings Release ”), and will continue to do so in future filings. • Confirm that you will disclose, at a similar level as you provided in your response letter dated September 18, 2025, the reasons why management believes that adjusting for income/loss relating to equity method securities and the gain/loss on debt securities carried at fair value in arriving at adjusted diluted net loss per share provides useful information to investors; and We respectfully…

The Company respectfully clarifies that the previously disclosed “gross amount of revenue” was intended as an operational metric. In response to the Staff’s comment, the Company respectfully undertakes to revise the relevant disclosure in its future Form 20-F filings as follows (with deletions shown in strikethrough showing the changes against the disclosure in the 2024 Form 20-F), subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed. “ NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS … 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES … (s) Revenue recognition … 5 CPaaS revenues The Company accounts for revenue from customers’ usage of text message and voice call services on the Company’s CPaaS platform as two separate performance obligations. The Company’s service fees are determined by applying the contractual…

The Company respectfully acknowledges the Staff’s comment and advises the Staff as follows: Accounting for Pre-Acquisition Hardware Deliveries in Purchase Price Allocation Under U.S. GAAP, consistent with ASC 606, hardware and subscription services are identified as separate performance obligations. Hardware revenue is recognized at a point in time when control of the hardware transfers to the customer, while revenue related to subscription services is recognized over time as the services are provided. Accordingly, under U.S. GAAP, hardware revenue is recognized when control is transferred to the customer, with a related contract asset, rather than deferring revenue over a period. The Company accounted for hardware sales made by Fleet Complete prior to the acquisition date in the purchase price allocation under ASC 805. Specifically, hardware deliveries made by Fleet Complete prior to…

The Company acknowledges the Staff’s comment and respectfully advises that the Company believes that free cash flow is an important performance metric for measuring the Company’s performance for investors, and the Company does not consider this metric to be a liquidity measure. Due to the Company’s unique history, a sizable amount of the Company’s value is recorded at a zero-book basis ( i.e. , approximately 800,000 surface acres and approximately 455,000 gross royalty acres in West Texas), resulting in a low book value for the Company. Further, each of the Company’s business segments has high margins with low capital expenditure requirements, and the Company maintains a conservative capital structure with limited to no debt. As noted in Note 11, “Income Taxes” of the Company’s Consolidated Financial Statements included in its Form 10-K for the fiscal year ended December 31, 2024, the…

In response to the Staff’s comment, we will revise our future filings to remove the presentation of our full non-GAAP income statement starting with the Quarterly Financial Supplement for the quarter ended September 30, 2025 that will be included as Exhibit 99.2 to our Current Report on Form 8-K, and in other applicable future filings.

In response to the Staff’s comment, we will update our future filings to revise the description of each non-GAAP financial measure using a different line-item name, for example, adjusted net revenues, adjusted net income. adjusted earnings per diluted common share, adjusted earnings per diluted common share available to common shareholders, etc., starting with the Quarterly Financial Supplement for the quarter ended September 30, 2025 that will be included as Exhibit 99.2 to our Current Report on Form 8-K, and in other applicable future filings. ***** In responding to the Staff’s comments, the Company acknowledges that it 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. If you have any questions or comments regarding the above information, please do not hesitate to…

The Company acknowledges the Staff’s comment regarding the subcontracted transportation and fuel reconciling item within the non-GAAP Operating revenue measure. Beginning with the Company’s next filing of the Quarterly Report on Form 10-Q for the quarter ending September 30, 2025, the Company will separately disclose subcontracted transportation and fuel in the reconciliation of Total revenue to Operating revenue on a consolidated and segment-level basis. For illustrative purposes, the Company has provided an example below of the disclosure that will be presented prospectively in the reconciliation of consolidated Total revenue to Operating revenue using the information from our most recent Form 10-K. 2333 Ponce de Leon Blvd., Suite 700, Coral Gables, Florida 33134 www.ryder.com September 26, 2025 Page 2 (In millions) 2024 2023 2022 Total revenue $ 12,636 $ 11,783 $ 12,011 Subcontracted…

In future filings, the Company will include all applicable disclosure requirements of Item 10(e) of Regulation S-K for non-GAAP measures used. We believe that the presentation of non-GAAP Operating Income provides important supplemental information to management and investors about financial and business trends relating to the company’s financial condition and results of operations. We propose to include the following table within our future releases on Form 8-K to quantify and provide a reconciliation for GAAP to non-GAAP Operating Income. 2 CME Group Inc. and Subsidiaries Adjusted Revenue, Operating Expense and Operating Income Reconciliation (dollars in millions, except per share amounts; shares in thousands) Quarter Ended September 30, Nine Months Ended September 30, 2025 2024 2025 2024 Total Revenues $ XXX $ XXX $ XXX $ XXX Real estate-related costs (credits) XXX XXX XXX XXX…

We respectfully acknowledge the Staff’s comment and advise the Staff that in future filings, we will not include the measure of “loss from operating activities, adjusted for non-cash items” within our disclosures. Rather, the Company will disclose its non-cash items separately and in accordance with U.S. generally accepted accounting principles (“ GAAP ”). The Company is providing the following proposed disclosure utilizing the Company’s 2024 Annual Report for illustrative purposes: The $174.3 million of net cash used by operating activities during the year ended December 31, 2024 was primarily due to loss from operating activities of $258.8 million, a favorable impact from non-cash items such as depreciation and amortization, non-cash operating lease costs, stock-based compensation, gain on sale of intangible assets, and loss from equity method securities, of $115.3 million, and cash…

• Revise your description on page 8 of the adjusted diluted net loss per share calculation to include the adjustment for gain/loss on debt securities carried at fair value. We respectfully acknowledge the Staff’s comment. In future filings, to the extent applicable, we will revise the description to include the adjustment for gain/loss on debt securities carried at fair value as it relates to adjusted diluted net loss per share. • Tell us why you only present this measure for the most recent period, while you presumably utilize this measure for a period-to-period comparison. We respectfully acknowledge the Staff’s comment. In our earnings release for the fiscal year ended December 31, 2024, furnished with the Commission on February 24, 2025 under Item 2.02 of our Current Report on Form 8-K (the “ 2024 Earnings Release ”), we presented a non-GAAP measure of adjusted diluted net loss per…

We acknowledge the Staff’s comment and respectfully advise the Staff that in future filings, we will include a reconciliation of operating netback to the most directly comparable GAAP measure gross profit. In our Management Discussion and Analysis (“MD&A”) reported on Form 10-Q and earnings press release for the quarter ended September 30, 2025, and in future applicable filings, we intend to extend the disclosure of consolidated and by segment gross profit in the results of operations section and provide the reconciliation of consolidated gross profit to non-GAAP measure operating netback in the non-GAAP measures section and by segment in the results of operations section. For the Staff’s reference, please see the proposed disclosures below illustrating how the Company plans to present consolidated gross profit in applicable future filings, as applied to our 2024 Form 10-K: (Thousands…

We acknowledge the Staff’s comment and will revise our disclosure in future filings to provide a reconciliation of net debt to the most directly comparable GAAP measure, total debt (notes payable), and net debt to capital ratio to the most directly comparable GAAP measure, debt to capital ratio. Additionally, for each period presented, we will include the comparable GAAP-based ratio to ensure alignment with Item 10(e)(1)(i)(A) and (B) of Regulation S-K and related Compliance and Disclosure Interpretations guidance. An example of our revised disclosure format is as follows: Net Debt to Capital Ratio Reconciliation The following table reconciles net debt to capital ratio (a non-GAAP financial measure) to debt to capital ratio, which is the GAAP financial measure that our management believes to be most directly comparable (dollars in thousands): Year Ended December 31, 2024 2023 Total debt…

Average fuel margin per gallon is a non-GAAP financial measure that the Company previously disclosed in its periodic reports. Because the Company’s management does not currently believe that presentation of average fuel margin per gallon provides useful information to investors regarding the Company’s financial condition and results of operations, management has determined that it will no longer disclose average fuel margin per gallon in its periodic reports going forward. Accordingly, the Company did not include average fuel margin per gallon in the Q2 2025 10-Q. The Company calculated average fuel margin per gallon by subtracting cost of sales specific to fuel purchases and merchant fees from net sales and dividing it by the number of gallons delivered in the reporting period. The tables below provide information regarding the components and calculation of average fuel margin per…

The Company acknowledges the Staff’s comment and, notwithstanding its continued belief that the calculation and presentation of Core AOI is not misleading and is useful to investors, has determined that, beginning with the release of third quarter financial results, we will no longer present Core AOI in our Earnings Conference Call Presentation. We will continue to provide investors with enhanced transparency and clarity regarding the Company’s operating results, including as compared to management’s expectations, set forth on Exhibit A hereto. * * * We appreciate the opportunity to respond to your comments. If you have any questions or require additional information, we would appreciate the opportunity to discuss these matters with you. If you wish to contact us directly, please feel free to call Brian Spitser, the Company’s Chief Disclosure Counsel, at (973) 802-7848, or me at (973)…

The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 176 and 177 to enhance clarity and ensure that investors are able to reconcile the “Change in Fair Value of Digital Assets and Related Investments” amounts to the corresponding amounts disclosed in the footnotes. September 2, 2025 Page 8 The Company further advises the Staff that, with respect to the Domestic Solana Fund, the Company acknowledges that investors are not able to directly reconcile such amounts for the fiscal years ended December 31, 2024 and 2023 with the revised disclosures to Note A of the combined consolidated financial statements on page 177, as the Company did not present a summary of changes in its equity investments for those periods. Beginning with the fiscal quarter ended June 30, 2025, however, the Company has included a summary of changes in its equity investments…

The Company acknowledges the Staff’s comment regarding the requirements in ASC 280-10-50-30(b) and ASC 280-10-50-28C as well as regarding the appearance of creating non-GAAP measures of consolidated EBIT and consolidated Adjusted EBIT. In future filings we will revise the presentation to remove such amounts. Additionally, the reconciliation of reportable segments’ Adjusted EBIT and Total segment Assets will be changed to include single amounts for the subtotal of segments’ Adjusted EBIT and Total segment Assets that are then reconciled to consolidated income before taxes and Total consolidated assets, respectively, as shown below in the revised Form 10-K disclosure. Further, the reconciliation of Other Segment Information will be revised to include single amounts for the subtotal of Total segment capital expenditures and Total segment depreciation and amortization that are then…

We will revise the table for the reconciliation of Total Adjusted EBITDA to begin with the GAAP measure of Net income attributable to Gannett, consistent with the guidance set forth in Question 102.10(b) of the Commission’s Compliance and Disclosure Interpretations for Non-GAAP Financial Measures. We will include the revised presentation in future filings, beginning with the Company’s quarterly report on Form 10-Q for the quarter ending September 30, 2025 and in future earnings releases furnished on Form 8-K, including revisions to Table 5, as applicable. * * * * * If you have any questions or comments regarding these responses or require any additional information, please do not hesitate to contact me at tgosser@gannett.com or (571) 405-0574. Very truly yours, /s/ Trisha Gosser Trisha Gosser Chief Financial Officer

The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 155 and 161 to align with the financial statements. The Company further advises the Staff that Non-GAAP disclosures on pages 172 and 173 to include the changes in fair value of the digital assets it holds directly as well as its ratable investment in the Domestic Solana Fund which primarily holds Solana tokens. Combined Consolidated Statements of Cash Flows, page F-57

We acknowledge the Staff’s comment and respectfully advise the Staff that in future filings, we will include a reconciliation of operating netback to the most directly comparable GAAP measure. Generally, issuers in the oil and gas industry do not present gross profit measure because the expenses reflected in gross profit do not accurately reflect the expenses customary to oil and gas industry operations that are integral to operating netback. Further, our operating costs do not include any depletion, depreciation and accretion expenses as those are not directly attributable to operating costs, but rather, due to the nature of oil and gas industry, reflect the amortization of assets associated with the development of our oil and gas properties and accretion of asset retirement obligation. In our view, operating netback is more directly comparable to net income (loss) as the closest…

In the Company’s response to the Staff’s comment regarding the presentation of pass-through costs also recognized as revenue to arrive at Non-GAAP net revenue on May 27, 2025, the Company noted that a portion of the Company’s Facilities Management (“FM”) and Project Management contracts include a margin on pass-through costs. However, the margin earned on these contracts in 2024 was immaterial, representing 0.2% of gross revenue and 0.5% of pass-through costs also recognized as revenue, respectively. The estimated margin was based on explicit fees contractually earned on pass-through costs. Although the explicit margin on pass-through costs is not material to the Company’s gross revenue or pass-through costs, the Company considered if there is an implicit margin on any of its pass-through costs given the various contract structures for the fees earned. For example, the Company in the…

The Company acknowledges the Staff’s comment and will revise the Management’s Discussion and Analysis of Financial Condition and Results of Operations section in future filings to ensure that discussion of non-GAAP financial information follows the discussion of the Company’s GAAP Results of Operations. This change will be reflected beginning with the Q2 2025 Form 10-Q. 1 Consolidated Financial Statements (18) Segment Information and Information about Geographic Areas, page 91

We acknowledge the Staff’s comment and respectfully advise the Staff that we will revise our non-GAAP measures in future filings, including prior periods presented, to remove the adjustment that excludes step-up depreciation of property, plant and equipment associated with prior acquisitions. * * * * We appreciate the opportunity to respond to your comment. If you have any questions with respect to this letter or if you require additional information, please feel free to contact me directly at 972-740-2989. Sincerely, /s/ Richard Heppenstall Richard Heppenstall Executive Vice President, Chief Financial Officer and Treasurer of ZimVie Inc. cc: Heather Kidwell, ZimVie Inc. 2

We will revise our segment information presentation included in the Use of Non-GAAP Information section in our quarterly earnings press releases to align with our financial reporting in the Form 10-Q. Specifically, we will remove the presentation of net income by segment and continue to focus on Adjusted EBITDA as the key performance measure, consistent with our internal reporting and the CODM's evaluation of segment results.

We hereby confirm that we will include directly in future Item 2.02 Forms 8-K all of the disclosures required by Item 10(e)(1)(i) of Regulation S-K for each non-GAAP measure presented, regardless of whether a non-GAAP measure is also presented in a Form 10-K or Form 10-Q. Thank you for the opportunity to respond to your comment. If you have additional questions or comments, please contact the undersigned at kcwong@asiafingroup.com or +60 123733783. Very truly yours, /s/ Kai Cheong Wong Kai Cheong Wong Chief Executive Officer

We acknowledge the Staff’s comment and respectfully advise the Staff that in future filings, we will expand the footnotes to our non-GAAP measure adjustments to quantify each material component when there are multiple components in the adjustment. Set forth below is an illustrative example of how we intend to expand our disclosures in future filings, utilizing footnote 1 as an example. [1] Restructuring activities to better position the organization and the expenses incurred were primarily related to employee termination benefits ($5.5 million and $2.8 million for the years ended December 31, 2024 and 2023, respectively) and professional fees ($0.2 million and $1.7 million for the years ended December 31, 2024 and 2023, respectively). 2 Additionally, we will clarify in future filings that our non-GAAP adjustment item entitled “Tax effect of above adjustments & other” represents the…

We acknowledge the Staff’s comment and respectfully advise the Staff of the following: • As discussed in our response to Comment No. 2 above, in future filings, we will expand our footnotes to our non-GAAP adjustments to quantify each material component when there are multiple components of the adjustment. • “Other charges” in the referenced filing reflected only step-up amortization of property, plant and equipment from prior acquisitions for continuing operations. The reference to “inventory write-offs resulting from restructuring activities” was language used in prior periods for discontinued operations and was inadvertently still included within the description. As a result, no inventory write-offs for continuing operations were classified or included as “restructuring” or “other charges” in the non-GAAP adjustments in the periods presented. • We have reviewed the referenced…

We acknowledge the Staff’s comment and respectfully advise that we have reviewed the referenced guidance (Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures) with regard to the exclusion of certain professional services in the adjustment of certain non-GAAP financial measures. Professional services fees incurred in connection with exploring potential transactions are outside the normal operations of a company. We do not consider professional services fees related to the evaluation of strategic alternatives for our portfolio to reflect normal operating expenses that are necessary to operate the Company’s business.

In response to the Staff’s comment, the Company has revised its disclosure in the cover art and on pages 2 and 155 of Amendment No. 1. U.S. Securities and Exchange Commission July 21, 2025 Page 2 Notes to the Consolidated Financial Statements Note 17. Subsequent Events (Unaudited), page F-51

The Company confirms that it will not present full non-GAAP consolidated income statements or their equivalents in future filings. Enclosed with this letter is an example of how the Company proposes to present the non-GAAP reconciliation tables in future filings, using the non-GAAP data from pages 7 and 8 of the referenced filing as an example. ​ We hope that we have sufficiently responded to your comments. If you have additional questions or comments, please contact me directly. ​ Best regards, ​ ​ ​ Kimberly A. Baber ​ Enclosure ​ c: Mr. Michael Cole, Chief Financial Officer (via email) ​ 27623305 ​ UFP Industries, Inc. Page 8 ​ RECONCILIATION OF NET EARNINGS TO ADJUSTED EBITDA BY SEGMENT (UNAUDITED) FOR THE THREE MONTHS ENDED MARCH 2025/2024 ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Quarter Period and Year to Date 2025 (In thousands) ​ Retail ​ Packaging ​ Construction ​ All Other…

We acknowledge the Staff’s comment, and, as a threshold matter, believe it is important to note that core AOI is one of the primary measures we and our investors use, together with our GAAP results, to assess the profitability and future earnings potential of our business. Core AOI provides this insight by excluding the impact of items that we believe are not typically indicative of our ongoing operations or future performance and/or that can vary significantly from period to period, including seasonal items and market driven variances that are beyond our control. For these reasons, we refer to these non-recurring items – those adjustments referenced in the Staff’s comment – as “non-core,” and exclude them when calculating core AOI. With regard to the first bullet in the Staff’s comment, we have set forth below a description of each of the referenced non-core adjustments, the reasons we…

We note Item 10(e) of Regulation S-K and the disclosures required thereby regarding non-GAAP financial measures. In our press releases dated May 13, 2025 and the correction dated May 23, 2025 (together the “Press Releases”), both of which were attached as exhibits to the Current Report on Form 8-K filed with the Commission on June 3, 2025, we cited several financial measures relating to our financial results for the quarter ended March 31, 2025, one of which was “EBITDA”, which we acknowledge is a non-GAAP financial measure within the meaning of Item 10(e)(2) of Regulation S-K. We note that the presentation of EBITDA in the Press Releases (in compliance with Item 10(e)(1)(i) of Regulation S-K) did not give such non-GAAP financial measure any greater prominence than that given to the directly comparable financial measure or measures calculated and presented in accordance with GAAP. The…

The Company acknowledges the Staff’s comments and has revised its disclosure on pages 9-12 to provide further context for the preliminary revenue and net income (loss) estimates. The Company respectfully advises the Staff that its financial closing procedures for the three months ended June 30, 2025 are not complete and it believes these financial statements and, accordingly, specific numbers for the three months ended June 30, 2025, are not yet available and will not be available prior to the effective date of the Amendment. The Company respectfully submits that, when included in a subsequent filing, the ranges for revenue, cost of sales (excluding depreciation and amortization), operating and administrative expenses, net income (loss), basic and diluted earnings (loss) per share, and the Non-GAAP financial measures disclosed on page 10 of the Amendment will be sufficiently narrow to…

The Company respectfully submits the following explanations regarding the nature of the further broken down adjustments included in “Other” and why management believes they are appropriate to include as non-recurring items in our EBITDA reconciliation. In each case, these adjustments reflect costs that are not part of our normal, ongoing operations, are non-recurring in nature, and are not expected to recur in future periods. These adjustments are consistent with Question 100.01 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures, as they do not substitute individually tailored accounting principles and do not exclude recurring cash operating expenses necessary to operate our business. The below includes additional details included in footnote (g) “Other”. Securities and Exchange Commission July 8, 2025 Page 3 (iv)…

In response to the Staff’s comment, the Company acknowledges the Staff’s request and will remove the Adjusted Net Earnings – Management View from future filings. * * * If Staff should have any questions or comments regarding this submission or response, please feel free to contact me at (310) 442-8828. Thank you for your ongoing courtesy in this matter. Sincerely, Alan A. Lanis, Jr. Partner

We acknowledge the Staff’s comment and appreciate the clarification regarding the presentation of segment profitability measures in the MD&A. In response to the Staff’s June 5, 2025 comment, we had proposed including line items for “Corporate, eliminations and other” and “Consolidated Adjusted EBITDA” within our segment Adjusted EBITDA table in the MD&A, in order to reconcile the total of segment results to the consolidated Adjusted EBITDA amounts disclosed on page 38 of the Form 10-K. Based on the Staff’s most recent comment, we understand that using terminology such as “Corporate, eliminations and other” may imply the presentation of a reconciling item consistent with ASC 280-10-50-30, which is required to appear in the footnotes to the financial statements and not within the MD&A. We also understand that including a “Corporate, eliminations and other” row could cause confusion when…

The Company respectfully acknowledges the Staff’s comment. The Company advises the Staff that in future periodic reports, as well as the Company’s press releases furnished under Item 2.02 of Form 8-K, when the Company presents a non-GAAP measure, it will present the most directly comparable GAAP measure with equal or greater prominence. The Company confirms when presenting Adjusted EBITDA, it will include a presentation of Net income with equal or greater prominence. Notes to the Consolidated Financial Statements Note 22 - Reportable Segment Information, page 90 2.

The Company’s cost of revenue for both freight brokerage and dedicated services is entirely comprised of the costs our carriers incur and invoice us to perform the service. In the case of freight brokerage services, this reflects their total costs for hauling the customers freight from origin to destination. In the case of dedicated capacity services, this reflects having the trucks available to haul freight for the customer and costs related to any freight movements. For both services, these costs include any accessorial charges carriers may incur such as loading or unloading, drayage, stoppage, fuel surcharges, border-crossing, packing materials, etc. The Company’s depreciation and amortization costs relate to the Company’s use over time of internally developed software, computer equipment, furniture, and our internet domain name. The Company considers all such costs to be operating…

The Company acknowledges and appreciates the Staff’s review of its filings. We have considered the Staff’s comment and will include the enhancements suggested in your comment, as relevant, in our future local Annual Report to Security Holders. The Company, however, respectfully submits that as a foreign private issuer its local Annual Report to Security Holders is furnished to the Commission pursuant to Rule 13a-16 and 15d-16 under the Securities Exchange Act of 1934 (the “ Exchange Act ”) and is not deemed to be “filed” for purposes of Section 18 of the Exchange Act or Item 10(a) of Regulation S-K. Accordingly, consistent with the Staff’s position in Financial Reporting Manual Section 8140, the requirements of Item 10(e) of Regulation S-K and interpretive guidance in Question 102.10(a) of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations do not apply to the…

The Company confirms that it will no longer include an adjustment for acquired in-process research and development expense in any non-GAAP financial measure presented in the future. If you have any additional questions or require any further information with respect to this response, please contact the undersigned by telephone at (858) 366-6900 or by email at lvosseller@tandemdiabetes.com. Sincerely, /s/ Leigh A. Vosseller Leigh A. Vosseller Chief Financial Officer Tandem Diabetes Care, Inc. 12400 High Bluff Drive – ››› – San Diego, CA 92130 – ››› – (858) 366-6900 – ››› – tandemdiabetes.com 1

The Company respectfully acknowledges the Staff’s comment and in future filings will revise its disclosure to remove EBITDA from its reconciliation of Net Income (Loss) to Adjusted EBITDA and update its definition of Adjusted EBITDA accordingly. If the Company determines to disclose EBITDA in the future, it will only present adjustments specifically identified by the acronym. Amer Sports, Inc. 149 Fifth Avenue, 9th Floor New York, NY 10010 Tel. +1 773 714-6400 www.amersports.com

The Company acknowledges the Staff’s comment and respectfully submits the following rationale for the Purchase Price Adjustment included in our determination of Adjusted Net Income (Loss) and certain other non-IFRS measures. This adjustment relates to amortization and depreciation arising from the step-up in fair value of intangible and tangible assets following the 2019 acquisition of Amer Sports. The specific facts and circumstances related to the Company’s acquisition history are a determining factor for understanding the components of the adjustment, how each amount was determined, and why the Company believes the adjustment is appropriate and complies with Question 100.04 of the Compliance & Disclosures Interpretations on Non-GAAP Financial Measures. In 2019, Amer Sports was acquired by an international investment consortium (the “Acquisition”). In connection with the Acquisition,…

We acknowledge the Staff’s comment and respectfully advise that the segment Adjusted EBITDA amounts presented on page 34 of the Form 10-K reflect the segment profit measure used by our Chief Operating Decision Maker to assess performance and allocate resources, as required under ASC 280. These amounts are presented on a reportable segment basis and do not include results from non-reportable segments and certain corporate-level activity. Separately, the consolidated Adjusted EBITDA amounts disclosed on page 38 of the Form 10-K represent a company-wide non-GAAP performance measure that includes contributions from non-reportable segments and corporate-level activity not reflected in the reportable segment-level results. We acknowledge that the total of reportable segment Adjusted EBITDA differs from consolidated Adjusted EBITDA and recognize that disclosing a subtotal of segment Adjusted…

We acknowledge the Staff’s comment and will remove both the consolidated EBITDA and consolidated Adjusted EBITDA line items from the segment note to the financial statements in future filings.