United States securities and exchange commission logo
August 31, 2022
Jeffrey Likosar
Chief Financial Officer
ADT Inc.
1501 Yamato Road
Boca Raton, Florida 33431
Re: ADT Inc.
Form 10-K for
Fiscal Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-38352
Dear Mr. Likosar:
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 this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis
Results of Operations, page 51
1. We note several
instances in which two or more factors are cited as a cause of a variance
in results of
operations between periods, with references to offsetting items in some cases,
without quantification.
To the extent practicable, please quantify each factor cited so that
investors may
understand the magnitude and relative impact of each on your results. Refer
to Item 303 of
Regulation S-K and section 501.04 of the staff s Codification of Financial
Reporting Policies for
guidance. Please note this comment also applies to disclosure in
your quarterly reports
on Form 10-Q.
Jeffrey Likosar
FirstName
ADT Inc. LastNameJeffrey Likosar
Comapany
August 31, NameADT
2022 Inc.
August
Page 2 31, 2022 Page 2
FirstName LastName
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 Abe Friedman at 202-551-8298 or Theresa Brillant at
202-551-
3307 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services