View:
United States securities and exchange commission logo
April 18, 2023
Timothy D. Boswell
President and Chief Financial Officer
WillScot Mobile Mini Holdings Corp.
4646 E Van Buren St. , Suite 400
Phoenix , Arizona 85008
Re: WillScot Mobile
Mini Holdings Corp.
Form 10-K for
Fiscal Year Ended December 31, 2022
Filed February 22,
2023
File No. 001-37552
Dear Timothy D. Boswell:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Consolidated Results of Operations
Business Segment Results, page 41
1. In future filings
please quantify, discuss, and analyze changes in consolidated costs of
leasing and services
and consolidated costs of sales and for each segment on a stand-alone
basis in addition to
your current disclosure which is made in the context of gross profit. In
your revised
disclosure, please consider quantifying and discussing the significant
components of these
costs to the extent material. Please provide to us in your response
your proposed revisions
as they would apply to your current presentation.
Timothy D. Boswell
FirstName LastNameTimothy D.Corp.
Boswell
WillScot Mobile Mini Holdings
Comapany
April NameWillScot Mobile Mini Holdings Corp.
18, 2023
April 218, 2023 Page 2
Page
FirstName LastName
2. We note that you have not included a comparative discussion of your
Storage Segment's
results of operations for the Years Ended December 31, 2021 and 2020.
Please advise.
In closing, 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 Aamira Chaudhry at 202-551-3389 or Amy Geddes at 202-551-
3304 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services