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Targa Resources Corp. 811 Louisiana, Suite 2100 Houston, Texas 77002-1400 www.targaresources.com |
November 17, 2021
Division of Corporation Finance
Office of Energy & Transportation
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-3561
| Re: | Targa Resources Corp. |
Form 10-K for Fiscal Year Ended December 31, 2020
Response dated October 27, 2021
File No. 001-34991
Ladies and Gentlemen:
Set forth below are the responses of Targa Resources Corp. (the “Company”, “we,” “us” or “our”), to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated September 23, 2021, with respect to Form 10-K for Fiscal Year Ended December 31, 2020 (the “Form 10-K”) and Form 8-K dated August 5, 2021, File No. 001-34991(the “Form 8-K” and together with the Form 10-K, the “Subject Filings”).
For your convenience, each response is prefaced by the exact text of the Staff’s corresponding comment in bold, italicized text. All references to page numbers and captions correspond to the referenced Subject Filing unless otherwise specified.
Supplemental Response Filed October 27, 2021
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures
Our Non-GAAP Financial Measures, page 64
| 1. | We note your response to our prior comment 1. It appears that the Gross margin presented to reconcile to non-GAAP Adjusted gross margin is calculated without subtracting the Operating expenses line item. For the non-GAAP Adjusted gross margin measure you present, the most directly comparable GAAP-basis measure appears to be a fully burdened gross margin. Please revise your presentation accordingly. |
Securities and Exchange Commission
November 17, 2021
Page 2
RESPONSE:
We respectively acknowledge the Staff’s comment. In future filings, the Company will not present Adjusted gross margin or Adjusted operating margin at the consolidated level, beginning with the Company’s Form 10-K for the year ended December 31, 2021.
Please direct any questions that you have with respect to the foregoing or if any additional supplemental information is required by the Staff, please contact Thomas Zentner of Vinson & Elkins L.L.P. at (512) 542- 8449.
| Very truly yours, | ||
| TARGA RESOURCES CORP. | ||
| By: | /s/ Jennifer R. Kneale | |
| Name: | Jennifer R. Kneale | |
| Title: | Chief Financial Officer | |
Enclosures
| cc: | Thomas Zentner, Vinson & Elkins LLP |