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United States securities and exchange commission logo
January 3, 2024
Jonathan Lock
Senior Vice President, Chief Financial Officer
Chemours Co
1007 Market Street
Wilmington, Delaware 19801
Re: Chemours Co
Form 10-K for
Fiscal Year ended December 31, 2022
Form 8-K Filed
February 9, 2023
Response dated
December 22, 2023
File No. 001-36794
Dear Jonathan Lock:
We have reviewed your December 22, 2023 response to our comment
letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in
our December 13, 2023
letter.
Form 8-K Filed February 9, 2023
Exhibit 99.1
1. We note your response
to prior comment 2 regarding your presentation of adjusted
EBITDA margin only at
the segment level as your segment profit measure. However, we
note within the Segment
Financial and Operating Data section of your earnings press
releases that you
include the presentation of adjusted EBITDA margin at the consolidated
level. As such, we
continue to request that you present the most directly comparable
financial measure or
measures calculated and presented in accordance with US GAAP in
accordance with Item
10(e)(1)(i)(A) of S-K.
Jonathan Lock
Chemours Co
January 3, 2024
Page 2
Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters.
Sincerely,
FirstName LastNameJonathan Lock
Division of
Corporation Finance
Comapany NameChemours Co
Office of Industrial
Applications and
January 3, 2024 Page 2 Services
FirstName LastName