Business & Consumer Services

60 SEC staff comments and 29 disclosure examples from companies in this industry.

SIC codes included: 7389 Services-Business Services, NEC, 7990 Services-Miscellaneous Amusement & Recreation, 7011 Hotels & Motels, 7311 Services-Advertising Agencies, 7900 Services-Amusement & Recreation Services, 8742 Services-Management Consulting Services, 8731 Services-Commercial Physical & Biological Research, 7340 Services-To Dwellings & Other Buildings

Disclosure examples by topic

What the SEC staff asked companies in this industry

Business Description (Item 101) (20)Non-GAAP: Reconciliation & Usefulness (9)IFRS & Foreign Private Issuers (8)Risk Factors (8)Segment Reporting (ASC 280) (6)KPIs, Metrics & Earnings Calls (5)Capitalization, Equity & Escrow (4)MD&A: Results & Known Trends (4)Non-GAAP: Equal Prominence (3)R&D Expense Disclosure (3)ASC 606: Revenue Recognition (3)Concentrations & Receivables (2)

Lionsgate Studios Corp. (LION) · 2026-07-21 · Form 10-K for Fiscal Year Ended March 31, 2026 · Comment 1 Agreed to revise

Staff comment: We note your disclosure of gross contribution and gross contribution as a percentage of revenue for each of your segments. Please explain how you determined that these were not non-GAAP measures which would require a reconciliation to the most comparable GAAP measure. In this regard, we note that you disclose segment profit as your primary measure of segment performance. As gross contribution would appear to be an additional measure of segment performance, it would appear to be subject to Item 10(e)(1)(i) of Regulation S- K as it is not required to be disclosed by ASC 280. Please also explain how you determined which measure of segment performance was determined in accordance with the… letter →

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 →

Non-GAAP: Reconciliation & Usefulness Segment Reporting (ASC 280)

MARCUS CORP (MCS) · 2026-05-14 · The oration Form 10-K for the Fiscal Year Ended December 31, 2025 · Comment 1 · Consolidated Statements of Operations, page 55 Responded

Staff comment: Please tell us how you computed the fiscal 2024 debt conversion expense referencing authoritative literature you relied upon. In doing so, please explain why the repurchase impacted equity as evidenced by the "Convertible Senior note repurchase" line item in your Consolidated Statements of Shareholders' Equity. letter →

Debt, Equity & Derivatives

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-04-23 · · Comment 1 · 2024 (Unaudited and Presented on an IFRS basis), page F-24 Agreed to revise

Staff comment: As your June 30, 2025 annual audited financial statements are prepared in accordance with U.S. GAAP, all interim unaudited financial statements required in the registration statement must also be prepared under U.S. GAAP as required by Item 8.A.5 of Form 20-F. Note that while foreign private issuers are allowed to initially include more current published information, that published data accommodation does not waive the underlying requirement for consistent accounting standards in a registration statement. Please revise to disclose the following: • Revise to replace your current December 31, 2025 interim unaudited financial statement prepared under IFRS with financial statements prepared… letter →

Company response: In response to the Staff’s comments, we have revised our disclosures beginning on page F-24 of the Registration Statement to replace our current December 31, 2025 interim unaudited financial statement prepared under IFRS with financial statements prepared under U.S. GAAP and also revised other areas of the Registration Statement impacted by the change, including our capitalization table and Item 5. Operating and financial review and prospects. We appreciate the assistance the Staff has provided with its comments. response letter →

IFRS & Foreign Private Issuers Capitalization, Equity & Escrow

Sunstone Hotel Investors, Inc. (SHO, SHO-PH, SHO-PI) · 2026-04-13 · Form 10-K for the year ended December 31, 2025 Filed on February 27, 2026 Form 8-K filed on February 27, 2026 · Comment 1 · Unaudited Selected Statistical and Financial Data, page 2 Responded

Staff comment: We note your presentation of Adjusted FFO Attributable to Common Stockholders per Diluted share here and as part of your 2026 Outlook. In future periodic filings, please present with equal or greater prominence the most directly comparable measure calculated in accordance with GAAP for this non-GAAP financial measure. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the Division's Corporation Finance Interpretations on Non-GAAP Financial Measures. letter →

Company response: * * * * * response letter →

Non-GAAP: Equal Prominence Non-GAAP: Reconciliation & Usefulness Earnings per Share (ASC 260)

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-04-07 · · Comment 1 · Grow the Research and Development..., page 27 Awaiting / response not in dataset

Staff comment: We note your revisions in response to prior comment 3. Please address the following: • We note that your disclosure on page 6 indicates that one or more submissions to EMA would be required prior to commercializing Scenesse for treatment of EPP in adolescents. Accordingly please revise the gray bar in the table so that it does not extend into the “Commercial” column. • We note you are developing novel formulations of the melanocortin adrenocorticotropic hormone (“ACTH”) as NEURACTHEL® in multiple dosage forms. You disclose that the NEURACTHEL Instant candidate is a generic and that you have not conducted any clinical trials. Accordingly, please revise the graphic itself to reflect that you… letter →

Business Description (Item 101)

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-04-07 · · Comment 2 · Research and Development, page 35 Awaiting / response not in dataset

Staff comment: We note your revisions in response to prior comment 2, which we reissue in part. Please further revise your discussion related to your announced expansion of the VALLAURIX RD&I Centre to address the following: • Discuss and quantify the support that you are to receive under the five-year investment plan. Disclose whether you are receiving grants, loans and/or other forms of support. Also, discuss your material obligations under the contract as well as the term and termination provisions. • With reference to Items 4.D of Form 20-F, disclose an estimate of the amount of your planned expenditures for the expansion, including the amount of expenditures already paid. Clarify whether these… letter →

KPIs, Metrics & Earnings Calls IFRS & Foreign Private Issuers

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-04-07 · · Comment 3 · A. Operating Results - Research and Development, page 46 Awaiting / response not in dataset

Staff comment: We acknowledge your response to prior comment seven and partially reissue our comment. • Please revise to include in your disclosures a statement regarding whether you track direct research and development costs by program area. • Revise your disclosure to disaggregate 'Direct R&D clinical site and program costs' currently included in 'other costs' for each period presented. We do not believe potential competitive harm is a valid reason for omitting this material information. letter →

R&D Expense Disclosure

VISA INC. (V) · 2026-03-31 · Form 10-K for Fiscal Year Ended September 30, 2025 · Comment 1 · Non-GAAP financial results, page 41 Awaiting / response not in dataset

Staff comment: To avoid giving undue prominence to your non-GAAP results, please revise to present and discuss your non-GAAP results after your discussion and analysis of GAAP results. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Corporation Finance Interpretations 102.10(a). Results of Operations Net revenue, page 45 2. Increases in each component of net revenue appear to be primarily volume related. This factor appears to recur annually as the primary factor impacting your net revenue. Please discuss to the extent identifiable factors, such as macro-economic conditions and others, are the cause for the increased volume. To the extent there are known trends in the factors that materially impact… letter →

Non-GAAP: Equal Prominence Non-GAAP: Reconciliation & Usefulness MD&A: Results & Known Trends KPIs, Metrics & Earnings Calls

UNIFIRST CORP (UNF) · 2026-03-23 · oration Form 10-K for Fiscal Year Ended August 30, 2025 · Comment 1 · Note 15: Segment Reporting, page 61 Awaiting / response not in dataset

Staff comment: We note that the CODM uses segment revenues and segment operating income to assess performance and allocate resources. Please tell us how you considered the guidance in ASC 280-10-50-29(f) and the example at 280-10-55-54(c) to discuss how the CODM uses this measure in assessing performance and deciding how to allocate resources. letter →

Segment Reporting (ASC 280)

UNIFIRST CORP (UNF) · 2026-03-23 · oration Form 10-K for Fiscal Year Ended August 30, 2025 · Comment 2 · uses this measure in assessing performance and deciding how to allocate resources. Awaiting / response not in dataset

Staff comment: Please disclose the significant segment expenses categories and amounts that are regularly provided to your CODM for each of your reportable segments. Also disclose the total of other segment items that are included in the reported measures of segment profit and loss for your segments. Refer to ASC 280-10-50-26A and 50-26B. letter →

Segment Reporting (ASC 280)

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 1 · B. Capitalization and Indebtedness, page 4 Awaiting / response not in dataset

Staff comment: We acknowledge your response to prior comment four. Please revise to address the following: • Revise the total capitalization amount in the table to reconcile to the balance sheet rather than using market capitalization; • Include a double line underneath the cash and cash equivalents and short-term investments numbers to distinguish them from the capitalization line items; and • Explain what the 'All other assets' line item represents and why it is included in the table. letter →

Capitalization, Equity & Escrow

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 2 · Item 4. Information on the Company, page 22 Awaiting / response not in dataset

Staff comment: We note that your January 12, 2026 press release announced a significant expansion of your VALLAURIX Research, Development and Innovation (RD&I) Centre in Singapore. With reference to Items 4.D. and 10.C. of Form 20-F, please revise to discuss this project and its impact or advise. letter →

Business Description (Item 101)IFRS & Foreign Private Issuers

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 3 · Grow the Research and Development Capacities and Broaden Therapeutic Portfolio, page 27 Awaiting / response not in dataset

Staff comment: We note your response to prior comment 8, as well as the inclusion of the pipeline table appearing on page 28. In this regard: • We note that the row reflecting SCENESSE in adolescent EPP indicates that the next anticipated program milestone is a "filing in H2 2026." Please revise to clarify the relevant regulator or jurisdiction as appropriate. • Revise the row reflecting SCENESSE in adolescent and adult vitiligo to (1) clarify in a footnote or otherwise, that the ongoing Phase 3 CUV105 trial is evaluating SCENESSE with adjunctive phototherapy and not as a monotherapy and (2) to include the year in which you expect topline results from the CUV105 trial. • We note your disclosure on page 27… letter →

Business Description (Item 101)

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 4 · disclosure is a more appropriate place to discuss the PhotoCosmetics program. Awaiting / response not in dataset

Staff comment: We acknowledge your response to prior comment 11, which we reissue with respect to the bullet points below. In this regard, we note that your pipeline table should be a visual reflection of the narrative discussion in the prospectus, which discussion should provide proper context and thoroughly address all completed, ongoing, and planned preclinical and clinical trials of your material product candidates. • The pipeline table, and your narrative disclosure on page 28 regarding the expected marketing submission for NEURACTHEL in the EU, suggests that all clinical trials of NEURACTHEL for IS and MS are complete. However, it does not appear that the design of these clinical trials, or the… letter →

Business Description (Item 101)

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 5 · Page 3 Awaiting / response not in dataset

Staff comment: Please revise page 28 to disclose the jurisdiction(s) where you plan to apply for regulatory approval for SCENESSE in adolescent and adult vitiligo and in variegate porphyria, and, as appropriate, in which order. letter →

Business Description (Item 101)

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 6 · SCENESSE, page 28 Awaiting / response not in dataset

Staff comment: We note your statement that "[c]urrently, the largest market opportunity is seen in vitiligo..." To provide insight into the size of the market opportunity, please revise to discuss the estimated size of the vitiligo patient population in adolescents and adults worldwide and/or in markets that are material to your business prospects. Similarly, with respect to your late-stage NERUACTHEL program, provide the estimated size of the patient population with infantile spasms and acute exacerbations of MS, which you state you believe would benefit from NEURACTHEL treatment. letter →

Business Description (Item 101)

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 7 · Research and Development, page 46 Awaiting / response not in dataset

Staff comment: We acknowledge your response to prior comment 24 and partially reissue our comment. Please revise to disclose the following: • Whether you track your research and development costs by program area; and • As 'Other costs' is over 40% of 2025 research and development expense, please revise to quantify and disclose its components and whether this material trend is expected in future periods. letter →

R&D Expense Disclosure KPIs, Metrics & Earnings Calls

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 8 · Table of Contents, page F-1 Awaiting / response not in dataset

Staff comment: Please revise the table of contents to your Item 18 financial statements to address the following: • Revise to disclose the December 31, 2025 interim financial statements and notes thereto; and • Please distinguish that your interim financial statements are unaudited and presented on an IFRS basis, as opposed to your annual financial statements that are audited and presented on a U.S. GAAP basis. letter →

IFRS & Foreign Private Issuers

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 9 · Revenue, page F-8 Awaiting / response not in dataset

Staff comment: We acknowledge your response to prior comment 23 and partially reissue our comment. Please revise your footnotes or MD&A to disclose the amounts for each significant category of sales rebate and other variable consideration adjustment reflected in the periods presented. letter →

ASC 606: Revenue Recognition MD&A: Results & Known Trends

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 10 · periods presented. Awaiting / response not in dataset

Staff comment: We note your disclosure on page 35 that changes in pricing of SCENESSE, from which you have consistently generated over 90% of your product sales, may have a severe impact on your operations, that you do not offer rebates or discounts on SCENESSE beyond statutory requirements and that you aim for uniform pricing per jurisdiction. As it appears that uniform pricing may coexist with expected rebates and other variable consideration with EEA and U.S. national or private insurers, whether stated or implicit, tell us how you considered whether any non-uniform elements exist, and if so, whether they are variable consideration that should be estimated and constrained in determining your… letter →

ASC 606: Revenue Recognition

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 11 · Interim Condensed Financial Statements, page F-24 Awaiting / response not in dataset

Staff comment: Please revise your December 31, 2025 interim financial statements to include a header for each of the statements and notes that prominently include "IFRS" and "Unaudited" for immediate visibility to distinguish them from the U.S. GAAP annual statements. letter →

IFRS & Foreign Private Issuers

Clinuvel Pharmaceuticals Ltd (CUVL, CLVLF) · 2026-03-19 · · Comment 12 · Notes to the Condensed Financial Statements, page F-28 Awaiting / response not in dataset

Staff comment: Please revise the basis of presentation footnote to include that these statements are prepared according to IFRS as issued by the IASB to qualify for the reconciliation exemption under Instruction 4 of Item 8.A.5 of Form 20-F. letter →

IFRS & Foreign Private Issuers

MAXIMUS, INC. (MMS) · 2026-03-13 · Form 10-K for the Fiscal Year Ended September 30, 2025 Filed November 20, 2025 · Comment 1 · Non-GAAP and Other Measures, page 45 Awaiting / response not in dataset

Staff comment: Please begin the reconcilation of Adjusted EBITDA presented on page 46 with net income, the most directly comparable GAAP measure pursuant to Item 10(e)(1)(i)(B) of Regulation S-K and Questions 102.10(b) and 103.02 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures (C&DI's). Additionally, we note the presentation of Adjusted EBITDA margin. Please present the comparable measure computed on a GAAP basis pursuant to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the C&DI's. letter →

Non-GAAP: Reconciliation & Usefulness

MAXIMUS, INC. (MMS) · 2026-03-13 · Form 10-K for the Fiscal Year Ended September 30, 2025 Filed November 20, 2025 · Comment 2 · 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the C&DI's. Awaiting / response not in dataset

Staff comment: We note that you believe providing measures that exclude the impact of amortization is useful to investors in evaluating your core operations and results; however, these measures include revenue from core operations generated in part by acquired assets. Please revise to clarify that although amortization of intangible assets acquired through acquisitions is being excluded from the non-GAAP measures, the revenue generated from these assets is still included in the measure. letter →

Non-GAAP: Reconciliation & Usefulness

MAXIMUS, INC. (MMS) · 2026-03-13 · Form 10-K for the Fiscal Year Ended September 30, 2025 Filed November 20, 2025 · Comment 3 · Note 3: Business Segments, page 62 Awaiting / response not in dataset

Staff comment: Please tell us how your disclosure complies with the requirement to disclose how the chief operating decision maker uses the reported measures of segment profit or loss in assessing segment performance and deciding how to allocate resources pusuant to ASC 280-10-50-30(f). letter →

Segment Reporting (ASC 280)

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