SEC Comment Letter for FERRO CORP (CIK 0000035214) — Jul 6, 2020
FERRO CORP (CIK 0000035214)
Date: July 6, 2020 · CIK: 0000035214 · Accession: 0000000000-20-006002
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo July 6, 2020 Benjamin Schlater Chief Financial Officer FERRO CORPORATION 6060 Parkland Boulevard Suite 250 Mayfield Heights, Ohio 44124 Re:FERRO CORPORATION Form 10-K for the Year Ended December 31, 2019 Form 8-K Filed March 2, 2020 File No. 1-00584 Dear Mr. Schlater : We have reviewed your June 4, 2020 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our May 20, 2020 letter. Form 8-K Filed March 2, 2020 Table 12, page 19 1.We note your response to prior comment 3. Please revise to label the measure “adjusted free cash flow." Please refer to Question 102.07 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures.
FirstName LastNameBenjamin Schlater Comapany NameFERRO CORPORATION July 6, 2020 Page 2 FirstName LastName Benjamin Schlater FERRO CORPORATION July 6, 2020 Page 2 You may contact Nudrat Salik at (202) 551-3692 or Daniel Gordon at (202) 551-3486 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
July 6, 2020
Benjamin Schlater
Chief Financial Officer
FERRO CORPORATION
6060 Parkland Boulevard
Suite 250
Mayfield Heights, Ohio 44124
Re:FERRO CORPORATION
Form 10-K for the Year Ended December 31, 2019
Form 8-K
Filed March 2, 2020
File No. 1-00584
Dear Mr. Schlater :
We have reviewed your June 4, 2020 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
May 20, 2020 letter.
Form 8-K Filed March 2, 2020
Table 12, page 19
1.We note your response to prior comment 3. Please revise to label the measure “adjusted
free cash flow." Please refer to Question 102.07 of the Compliance and Disclosure
Interpretations for Non-GAAP Financial Measures.
FirstName LastNameBenjamin Schlater
Comapany NameFERRO CORPORATION
July 6, 2020 Page 2
FirstName LastName
Benjamin Schlater
FERRO CORPORATION
July 6, 2020
Page 2
You may contact Nudrat Salik at (202) 551-3692 or Daniel Gordon at (202) 551-3486
with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences