SEC Comment Letter 0000000000-23-013584 to CORNING INC /NY (GLW) (CIK 0000024741) (GLW)
CORNING INC /NY (GLW) (CIK 0000024741)
Date: Dec. 13, 2023 · CIK: 0000024741 · Accession: 0000000000-23-013584
AI Filing Summary & Sentiment
File numbers found in text: 001-03247
Letter
United States securities and exchange commission logo December 13, 2023 Edward Schlesinger Chief Financial Officer Corning Incorporated One Riverfront Plaza Corning, NY 14831 Re:Corning Incorporated Form 10-K for the Year Ended December 31, 2022 Form 10-Q for the Period Ended September 30, 2023 File No. 001-03247 Dear Edward Schlesinger: We have reviewed your December 1, 2023 response to our comment letter and have the following comment(s). 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 November 17, 2023 letter. Form 10-Q for the Period Ended September 30, 2023 Goodwill, page 27 1.We note your response and your conclusion that at September 30, 2023, after evaluating expectations for the long-term growth of the business, forecasted future cash flows and those set forth in ASC 350-20-35-3C, as well as your actual results and outlook, that it was not more likely than not that the fair values of your goodwill were less than their respective carrying values and, therefore, you did not have any impairment. Given the deterioration in your operating results (i.e., decreases in net sales and net income) and cash flows from operations, please refer to Item 303(b)(3) of Regulation S-K and expand your disclosures in future filings to address the following: •describe the potential events and/or changes in circumstances that could result in additional impairment charges; and •disclose the percentage by which your estimated fair value exceeds your carrying
FirstName LastNameEdward Schlesinger Comapany NameCorning Incorporated December 13, 2023 Page 2 FirstName LastName Edward Schlesinger Corning Incorporated December 13, 2023 Page 2 value as of the date of your most recent impairment test. Please contact Heather Clark at 202-551-3624 or Melissa Gilmore at 202-551-3777 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
December 13, 2023
Edward Schlesinger
Chief Financial Officer
Corning Incorporated
One Riverfront Plaza
Corning, NY 14831
Re:Corning Incorporated
Form 10-K for the Year Ended December 31, 2022
Form 10-Q for the Period Ended September 30, 2023
File No. 001-03247
Dear Edward Schlesinger:
We have reviewed your December 1, 2023 response to our comment letter and have the
following comment(s).
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 November 17, 2023
letter.
Form 10-Q for the Period Ended September 30, 2023
Goodwill, page 27
1.We note your response and your conclusion that at September 30, 2023, after evaluating
expectations for the long-term growth of the business, forecasted future cash flows and
those set forth in ASC 350-20-35-3C, as well as your actual results and outlook, that it
was not more likely than not that the fair values of your goodwill were less than their
respective carrying values and, therefore, you did not have any impairment. Given the
deterioration in your operating results (i.e., decreases in net sales and net income) and
cash flows from operations, please refer to Item 303(b)(3) of Regulation S-K and expand
your disclosures in future filings to address the following:
•describe the potential events and/or changes in circumstances that could result in
additional impairment charges; and
•disclose the percentage by which your estimated fair value exceeds your carrying
FirstName LastNameEdward Schlesinger
Comapany NameCorning Incorporated
December 13, 2023 Page 2
FirstName LastName
Edward Schlesinger
Corning Incorporated
December 13, 2023
Page 2
value as of the date of your most recent impairment test.
Please contact Heather Clark at 202-551-3624 or Melissa Gilmore at 202-551-3777 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing