SEC Comment Letter for ABBOTT LABORATORIES (ABT) — May 8, 2017
ABBOTT LABORATORIES
Date: May 8, 2017 · CIK: 0000001800 · Accession: 0000000000-17-016024
AI Filing Summary & Sentiment
Letter
May 8, 2017 Brian B. Yoor SVP, Finance and Chief Financial Officer Abbott Laboratories 100 Abbott Park Road Abbott Park, IL 60064 Abbott Laboratories Form 8-K filed January 25, 2017 File No. 001-02189Re: Dear Mr. Yoor: We have reviewed your April 11, 2017 response to our comment letter 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 the 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 the comment, we may have additional comments. Form 8-K filed January 25, 2017 Exhibit 99.1 NON-GAAP RECONCILIATION OF FINANCIAL INFORMATION FROM CONTINUING OPERATIONS, page 14 Regarding your response to our prior comment 1 of our March 29, 2017 letter, please confirm to us that you will revise your future filings to provide a similar level of detail regarding your non-GAAP adjustments. As part of such disclosure, clearly quantify each 'specified item' noted in the disclosure. For example, in the first table of 'Non-GAAP Reconciliation of Financial Information From Continuing Operations for the Fourth Quarter Ended December 31, 2016 and 2015' on page 14, you disclose that specified items reflect "...other expenses of $196 million, primarily associated with acquisitions, including bridge facility fees and other debt related costs, charges related to cost reduction initiatives and other expenses". In this regard, separately discuss and quantify each 'specified item' noted rather than an aggregate amount.1.
Brian B. Yoor Abbott Laboratories 2 PageMay 8, 2017 You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at 202-551-3494 with any questions. Division of Corporation Finance Office of Healthcare and Insurance
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May 8, 2017
Brian B. Yoor
SVP, Finance and Chief Financial Officer
Abbott Laboratories
100 Abbott Park Road
Abbott Park, IL 60064
Abbott Laboratories
Form 8-K filed January 25, 2017
File No. 001-02189Re:
Dear Mr. Yoor:
We have reviewed your April 11, 2017 response to our comment letter 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 the 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 the comment, we may have additional comments.
Form 8-K filed January 25, 2017
Exhibit 99.1
NON-GAAP RECONCILIATION OF FINANCIAL INFORMATION FROM CONTINUING
OPERATIONS, page 14
Regarding your response to our prior comment 1 of our March 29, 2017 letter, please
confirm to us that you will revise your future filings to provide a similar level of detail
regarding your non-GAAP adjustments. As part of such disclosure, clearly quantify each
'specified item' noted in the disclosure. For example, in the first table of 'Non-GAAP
Reconciliation of Financial Information From Continuing Operations for the Fourth
Quarter Ended December 31, 2016 and 2015' on page 14, you disclose that specified
items reflect "...other expenses of $196 million, primarily associated with acquisitions,
including bridge facility fees and other debt related costs, charges related to cost
reduction initiatives and other expenses". In this regard, separately discuss and quantify
each 'specified item' noted rather than an aggregate amount.1.
Brian B. Yoor
Abbott Laboratories
2 PageMay 8, 2017
You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at 202-551-3494 with
any questions.
Division of Corporation Finance
Office of Healthcare and
Insurance