December 19, 2022 |
VIA EDGAR
Mr. Stephen Kim
Ms. Theresa Brillant
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, N.E.
Washington, D.C. 20549
Re: | HyreCar Inc. |
Form 10-K for the Year Ended December 31, 2021
Filed March 15, 2022
File No. 001-38561
Dear Mr. Kim/Ms. Brillant:
Reference is made to your letter, dated December 7, 2022, to HyreCar Inc., a Delaware corporation (the “Company"), regarding comments from the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) in connection with the Company’s Annual Report on Form 10-K filed with the Commission on March 15, 2022. For your convenience, we have set forth your comment in bold italics below with the Company’s response following thereafter.
Form 10-K for the Fiscal Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Reconciliation of Non-GAAP Financial Measures, page 27
1. | Please remove the adjustment "changes in the liabilities for insurance reserves" to arrive at the non-GAAP measure Adjusted EBITDA in future filings. Refer to Question 100.01 and 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. |
RESPONSE: The Company respectfully acknowledges the Staff’s comment and represents to the Staff that it will remove the aforementioned adjustment in arriving at Adjusted EBITDA in all future filings.
Item 9A. Controls and Procedures, page 32
2. | Please amend your filing to provide the disclosures required by Item 308(a) of Regulation S-K. |
RESPONSE: The Company respectfully acknowledges the Staff’s comment and has simultaneously filed with this response letter Amendment No. 1 to Form 10-K for the year ended December 31, 2021 to include the required disclosure under Item 308(a) of Regulation S-K.
* * *
Securities and Exchange Commission
December 19, 2022
Page 2
Should you have any additional questions relating to any of the foregoing, please contact Shashi Khiani of Polsinelli PC at (202) 626-8312.
| Sincerely, |
| |
| /s/ Eduardo Iniguez | |||
| Interim Chief Executive Officer & Interim Chief | |||
| Financial Officer | |||
cc: | Shashi Khiani, Polsinelli PC |
Bryan Wasser, Polsinelli PC
