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United States securities and exchange commission logo
December 8, 2021
Jes s Llorca
Chief Financial Officer
SEACOR Marine Holdings Inc.
12121 Wickchester Lane
Suite 500
Houston, TX 77079
Re: SEACOR Marine
Holdings Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed March 12,
2021
File No. 001-37966
Dear Mr. Llorca:
We have reviewed your filing and have the following comment. In
our comment, we
may ask you to provide us with information so we may better understand
your disclosure.
Please respond to this comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2020
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Certain Components of Revenues and Expenses
Direct Vessel Profit, page 43
1. We note you have
identified the measure Direct Vessel Profit (DVP) as a non-GAAP
measure when applied to
individual vessels, fleet categories or the combined fleet. You
disclose that DVP is
defined as operating revenues less direct operating expenses
excluding leased-in
equipment expense. We also note your disclosure that DVP has some
limitations in that it
does not take into account all expense related to the operation of the
fleet and, more
significantly, the Company. Please address the following related to this
measure:
Clarify if the
operating revenues used in your calculation of DVP include leased-in
equipment revenue.
To the extent operating revenues include revenue from leased-in
Jes s Llorca
SEACOR Marine Holdings Inc.
December 8, 2021
Page 2
equipment, please explain why you believe it is appropriate to
exclude the related
costs and expenses in your non-GAAP presentation.
Tell us how you considered reconciling DVP to the most directly
comparable GAAP
measure, fully loaded GAAP gross margin. Refer to Item
10(e)(1)(i)(B) of Regulation
S-K.
We remind you that the company 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.
You may contact Myra Moosariparambil at 202-551-3796 or Craig Arakawa
at 202-551-
3650 if you have questions regarding the comment.
FirstName LastNameJes s Llorca Sincerely,
Comapany NameSEACOR Marine Holdings Inc.
Division of
Corporation Finance
December 8, 2021 Page 2 Office of Energy
& Transportation
FirstName LastName