SEC Comment Letter 0000000000-23-011985 to BALL Corp (BALL) (CIK 0000009389) (BALL)
BALL Corp (BALL) (CIK 0000009389)
Date: Nov. 2, 2023 · CIK: 0000009389 · Accession: 0000000000-23-011985
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo November 2, 2023 Howard Yu Chief FInancial Officer Ball Corporation 9200 W. 108 th Circle , P.O. Box 5000 Westminster , CO 80021-2510 Re:Ball Corporation Form 10-K for the year ended December 31, 2022 File No. 1-07349 Dear Howard Yu: We have limited our review of your filing to the financial statements and related disclosures 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 our 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. Form 10-K for the year ended December 31, 2022 Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of operations, page 23 1.We note your discussion of your results of operations, starting on page 23, that describe multiple factors that impacted these line items in each respective reporting period. For example, your Cost of Sales discussion describes the increase year-over-year is primarily due to higher manufacturing costs, general inflationary cost pressures and global supply chain transportation disruptions but does not quantify the component impact of each factor. In addition, we noted your Selling, General and Administrative, and Segment Results narratives include a partially offsetting driver without related quantification. In future filings, please revise to further describe material changes to a line item in both quantitative and qualitative terms for each disclosed component, including the impact of offsetting factors. Refer to Item 303(b) of Regulation S-K.
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
FirstName LastNameHoward Yu Comapany NameBall Corporation November 2, 2023 Page 2 FirstName LastName Howard Yu Ball Corporation November 2, 2023 Page 2 absence of action by the staff. Please contact Charles Eastman at 202-551-3794 or Melissa Gilmore at 202-551-3777 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
November 2, 2023
Howard Yu
Chief FInancial Officer
Ball Corporation
9200 W. 108 th Circle , P.O. Box 5000
Westminster , CO 80021-2510
Re:Ball Corporation
Form 10-K for the year ended December 31, 2022
File No. 1-07349
Dear Howard Yu:
We have limited our review of your filing to the financial statements and related
disclosures 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
our 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.
Form 10-K for the year ended December 31, 2022
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of operations, page 23
1.We note your discussion of your results of operations, starting on page 23, that describe
multiple factors that impacted these line items in each respective reporting period. For
example, your Cost of Sales discussion describes the increase year-over-year is primarily
due to higher manufacturing costs, general inflationary cost pressures and global supply
chain transportation disruptions but does not quantify the component impact of each
factor. In addition, we noted your Selling, General and Administrative, and Segment
Results narratives include a partially offsetting driver without related quantification. In
future filings, please revise to further describe material changes to a line item in both
quantitative and qualitative terms for each disclosed component, including the impact of
offsetting factors. Refer to Item 303(b) of Regulation S-K.
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
FirstName LastNameHoward Yu
Comapany NameBall Corporation
November 2, 2023 Page 2
FirstName LastName
Howard Yu
Ball Corporation
November 2, 2023
Page 2
absence of action by the staff.
Please contact Charles Eastman at 202-551-3794 or Melissa Gilmore at 202-551-3777
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing