SEC Comment Letter 0000000000-23-012160 to ILLINOIS TOOL WORKS INC (ITW) (CIK 0000049826) (ITW)
ILLINOIS TOOL WORKS INC (ITW) (CIK 0000049826)
Date: Nov. 7, 2023 · CIK: 0000049826 · Accession: 0000000000-23-012160
AI Filing Summary & Sentiment
File numbers found in text: 001-04797
Letter
United States securities and exchange commission logo November 7, 2023 Michael Larson Chief Financial Officer Illinois Tool Works, Inc. 155 Harlem Avenue Glenview, IL 60025 Re:Illinois Tool Works, Inc. Form 10-K For the Year Ended December 31, 2022 Filed on February 10, 2023 File No. 001-04797 Dear Michael Larson: 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 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. Form 10-K for the Year Ended December 31, 2022, Filed on February 10, 2023 Management's Discussion and Analysis Consolidated Results of Operations, page 21 1.We note your discussion of your results of operations does not directly address material changes in the consolidated expense line items cost of revenues and selling, administrative, and research and development. Please refer to Item 303(b) of Regulation S-K and discuss in future filings, qualitatively and quantitatively, the factors resulting in material changes in your reported consolidated expense line items, including a discussion of material changes within a line item where several factors offset one another. 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 absence of action by the staff.
FirstName LastNameMichael Larson Comapany NameIllinois Tool Works, Inc. November 7, 2023 Page 2 FirstName LastName Michael Larson Illinois Tool Works, Inc. November 7, 2023 Page 2 Please contact Joseph Kempf at 202-551-3352 or Robert Littlepage at 202-551-3361 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
November 7, 2023
Michael Larson
Chief Financial Officer
Illinois Tool Works, Inc.
155 Harlem Avenue
Glenview, IL 60025
Re:Illinois Tool Works, Inc.
Form 10-K For the Year Ended December 31, 2022
Filed on February 10, 2023
File No. 001-04797
Dear Michael Larson:
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 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.
Form 10-K for the Year Ended December 31, 2022, Filed on February 10, 2023
Management's Discussion and Analysis
Consolidated Results of Operations, page 21
1.We note your discussion of your results of operations does not directly address material
changes in the consolidated expense line items cost of revenues and selling,
administrative, and research and development. Please refer to Item 303(b) of Regulation
S-K and discuss in future filings, qualitatively and quantitatively, the factors resulting in
material changes in your reported consolidated expense line items, including a discussion
of material changes within a line item where several factors offset one another.
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
absence of action by the staff.
FirstName LastNameMichael Larson
Comapany NameIllinois Tool Works, Inc.
November 7, 2023 Page 2
FirstName LastName
Michael Larson
Illinois Tool Works, Inc.
November 7, 2023
Page 2
Please contact Joseph Kempf at 202-551-3352 or Robert Littlepage at 202-551-3361 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology