SEC Comment Letter for CORNING (GLW) — Feb 26, 2026
CORNING INC /NY (GLW) (CIK 0000024741)
Date: Feb. 26, 2026 · CIK: 0000024741 · Accession: 0000000000-26-002022
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-03247
Referenced dates: September 25, 2025
Letter
Re: Corning Incorporated Response Dated July 25, 2025 File No. 001-03247 Dear Edward Schlesinger:
February 26, 2026
Edward Schlesinger Chief Financial Officer Corning Incorporated One Riverfront Plaza Corning, NY 14831
We have reviewed your September 25, 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 August 27, 2025 letter.
Response Letter dated September 25, 2025 Response to Comment 1
1. We note your response to prior comment 1 regarding the constant-currency adjustment made in calculating your non-GAAP core performance measures. We also note that this adjustment is based on long-term management-determined rates, which are closely aligned with your hedging instrument rates. Please revise to remove this non-GAAP adjustment as it appears to be inconsistent with Rule 100(b) of Regulation G. 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.
Sincerely,
Division of
Corporation Finance
February 26, 2026
Page 2
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<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> February 26, 2026 Edward Schlesinger Chief Financial Officer Corning Incorporated One Riverfront Plaza Corning, NY 14831 Re: Corning Incorporated Response Dated July 25, 2025 File No. 001-03247 Dear Edward Schlesinger: We have reviewed your September 25, 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 August 27, 2025 letter. Response Letter dated September 25, 2025 Response to Comment 1 1. We note your response to prior comment 1 regarding the constant-currency adjustment made in calculating your non-GAAP core performance measures. We also note that this adjustment is based on long-term management-determined rates, which are closely aligned with your hedging instrument rates. Please revise to remove this non-GAAP adjustment as it appears to be inconsistent with Rule 100(b) of Regulation G. 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. Sincerely, Division of Corporation Finance February 26, 2026 Page 2 Office of Manufacturing </TEXT> </DOCUMENT>