September 5, 2024
Via EDGAR
Mr. Jeffrey Gordon
Ms. Anne McConnell
Division of Corporation Finance
Office of Manufacturing
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | JELD-WEN Holding, Inc. |
Form 10-K for the Fiscal Year Ended December 31, 2023
Form 8-K filed February 20, 2024
Form 8-K filed May 6, 2024
File No. 001-38000
Dear Mr. Gordon and Ms. McConnell:
This letter contains the response of JELD-WEN Holding, Inc., a Delaware corporation (the “Company”), to your letter dated August 30, 2024, setting forth a comment of the Staff (the “Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission regarding the above-referenced filings. For your convenience, we restated in italics the comment in the Staff’s comment letter.
Form 10-K for the fiscal year ended December 31, 2023
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Segment Results, page 45
| 1. | We note your non-GAAP reconciliations of Adjusted EBITDA on pages 46 and 47 include a subtotal column that you identify as “Total Operating Segments.” Since each subtotal in this column represents a non-GAAP financial measure that would not comply with Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures, please revise your reconciliations in future filings to delete this subtotal column. This comment is also applicable to your presentation of this subtotal column in the Segment footnote, in earnings releases filed under Form 8-K, and in quarterly filings. |
Response: The Company respectfully acknowledges the Staff’s comment and will remove the “Total Operating Segments” subtotal column in its non-GAAP reconciliations of Adjusted EBITDA in future periodic filings and earnings releases furnished on Form 8-K.
JELD-WEN, Inc. 2645 Silver Crescent Drive, Charlotte, NC 28273
USA www.jeld-wen.com