SEC Comment Letter for CORNING (GLW) — Jul 1, 2025
CORNING INC /NY (GLW) (CIK 0000024741)
Date: July 1, 2025 · CIK: 0000024741 · Accession: 0000000000-25-006925
AI Filing Summary & Sentiment
File numbers found in text: 001-03247
Referenced dates: June 20, 2025
Letter
July 1, 2025 Edward Schlesinger Chief Financial Officer Corning Incorporated One Riverfront Plaza Corning, NY 14831 Re:Corning Incorporated Response Dated June 20, 2025 File No. 001-03247 Dear Edward Schlesinger: We have reviewed your June 20, 2025 response to our comment letter 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 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 June 9, 2025 letter. Response Letter dated June 20, 2025 Response to Comment 1 1.We note your response to our prior comment 1. Please address the following: •Describe specifically the calculation of your core rates, including any actual inputs using your hedging instrument exchange rates and any estimated factors used therein and define what you describe as a blended basis •Describe in more detail, management's review process for setting and approving the core rates and why it was not deemed necessary to update your rates more frequently Please contact Melissa Gilmore at 202-551-3777 or Kevin Woody at 202-551-3629 if you have questions regarding comments on the financial statements and related matters.
July 1, 2025 Page 2 Sincerely, Division of Corporation Finance Office of Manufacturing
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July 1, 2025
Edward Schlesinger
Chief Financial Officer
Corning Incorporated
One Riverfront Plaza
Corning, NY 14831
Re:Corning Incorporated
Response Dated June 20, 2025
File No. 001-03247
Dear Edward Schlesinger:
We have reviewed your June 20, 2025 response to our comment letter 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 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 June 9,
2025 letter.
Response Letter dated June 20, 2025
Response to Comment 1
1.We note your response to our prior comment 1. Please address the following:
•Describe specifically the calculation of your core rates, including any actual
inputs using your hedging instrument exchange rates and any estimated factors
used therein and define what you describe as a blended basis
•Describe in more detail, management's review process for setting and approving
the core rates and why it was not deemed necessary to update your rates more
frequently
Please contact Melissa Gilmore at 202-551-3777 or Kevin Woody at 202-551-3629 if
you have questions regarding comments on the financial statements and related matters.
July 1, 2025
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing