SEC Comment Letter for BALL Corp (BALL) (CIK 0000009389) (BALL) — Apr 1, 2020
BALL Corp (BALL) (CIK 0000009389)
Date: April 1, 2020 · CIK: 0000009389 · Accession: 0000000000-20-002829
AI Filing Summary & Sentiment
File numbers found in text: 001-07349
Letter
April 1, 2020 Scott C. Morrison Chief Financial Officer Ball Corporation 10 Longs Peak Drive P.O. Box 5000 Broomfield, Colorado 80021-2510 Re:Ball Corporation Form 10-K for the Year Ended December 31, 2019 Filed February 19, 2020 File No. 001-07349 Dear Mr. Morrison: We have reviewed your filing 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 the Year Ended December 31, 2019 Financial Condition, Liquidity and Capital Resources Cash Flows and Capital Expenditures, page 28 1.Although the header indicates a discussion of cash flows and capital expenditures, we note no discussion of the changes in cash flows from investing and financing activities. Please revise to include detail of the nature of the cash flows in investing and financing activities including changes from year to year.
FirstName LastNameScott C. Morrison Comapany NameBall Corporation April 1, 2020 Page 2 FirstName LastName Scott C. Morrison Ball Corporation April 1, 2020 Page 2 Financial Statements Notes to the Consolidated Financial Statements 1. Critical and Significant Accounting Policies Significant Accounting Policies Inventories, page 45 2.We note your disclosure that inventories are carried at the lower of cost or market. Please tell us how this is consistent with ASC 330-10-35-1B which indicates that inventories should be valued at the lower of cost or net realizable value. 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 Heather Clark at 202-551-3624 or John Cash at 202-551-3768 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
April 1, 2020
Scott C. Morrison
Chief Financial Officer
Ball Corporation
10 Longs Peak Drive
P.O. Box 5000
Broomfield, Colorado 80021-2510
Re:Ball Corporation
Form 10-K for the Year Ended December 31, 2019
Filed February 19, 2020
File No. 001-07349
Dear Mr. Morrison:
We have reviewed your filing 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 the Year Ended December 31, 2019
Financial Condition, Liquidity and Capital Resources
Cash Flows and Capital Expenditures, page 28
1.Although the header indicates a discussion of cash flows and capital expenditures, we note
no discussion of the changes in cash flows from investing and financing activities. Please
revise to include detail of the nature of the cash flows in investing and financing activities
including changes from year to year.
FirstName LastNameScott C. Morrison
Comapany NameBall Corporation
April 1, 2020 Page 2
FirstName LastName
Scott C. Morrison
Ball Corporation
April 1, 2020
Page 2
Financial Statements
Notes to the Consolidated Financial Statements
1. Critical and Significant Accounting Policies
Significant Accounting Policies
Inventories, page 45
2.We note your disclosure that inventories are carried at the lower of cost or market. Please
tell us how this is consistent with ASC 330-10-35-1B which indicates that inventories
should be valued at the lower of cost or net realizable value.
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 Heather Clark at 202-551-3624 or John Cash at 202-551-3768 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing