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United States securities and exchange commission logo
April 8, 2024
Michael Randolfi
Chief Financial Officer
Sabre Corporation
3150 Sabre Drive
Southlake, TX 76092
Re: Sabre Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2023
Filed February 15,
2024
File No. 001-36422
Dear Michael Randolfi:
We have reviewed your
filing and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Note 19. Segment Information, page 95
1. Please disclose
revenues from external customers by reportable segment pursuant to ASC
280-10-50-22.
2. We note that Corporate
does not appear to be a reportable segment and should be
excluded from your
reportable segment total disclosed under Adjusted Operating Income
(Loss) in the table
on page 96. Accordingly, please revise your presentation of your
reportable segments
measure of profit or loss and the accompanying reconciliation to
comply with ASC
280-10-50-30(b). In this regard, the required reconciliation should
begin with your
reportable segments measures of profit or loss (excluding Corporate) and
be reconciled to your
consolidated income before income taxes. Allocations and other
adjustments (including
Corporate) should be made after your total reportable segments'
measure of profit or
loss. See also ASC 280-10-55-49.
3. Refer to your
presentation of your reportable segments measure of profit or loss. In light
of the adjustment to
eliminate intersegment revenue, it is unclear why you do not have an
Michael Randolfi
Sabre Corporation
April 8, 2024
Page 2
adjustment to eliminate intersegment profits. Please revise or advise
us.
4. Please delete the reconciliation of Operating income (loss) to the
non-GAAP measure
"Adjusted Operating Income (Loss)," appearing on page 96 of your GAAP
financial
statements.
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.
Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-3361
if you have questions regarding comments on the financial statements and
related matters.
FirstName LastNameMichael Randolfi Sincerely,
Comapany NameSabre Corporation
Division of
Corporation Finance
April 8, 2024 Page 2 Office of
Technology
FirstName LastName