SEC Comment Letter 0000000000-23-005846 to JACOBS SOLUTIONS INC. (J) (CIK 0000052988) (J)
JACOBS SOLUTIONS INC. (J) (CIK 0000052988)
Date: June 2, 2023 · CIK: 0000052988 · Accession: 0000000000-23-005846
AI Filing Summary & Sentiment
File numbers found in text: 001-07463
Letter
United States securities and exchange commission logo June 2, 2023 Kevin Berryman Chief Financial Officer JACOBS SOLUTIONS INC. 1999 Bryan Street Suite 1200 Dallas, Texas 75201 Re:JACOBS SOLUTIONS INC. Form 10-K for the year ended September 30, 2022 Filed on November 21, 2022 Form 8-K filed on February 7, 2023 File No. 001-07463 Dear Kevin Berryman: We have reviewed your May 26, 2023 response to our comment letter and have the following comment. In our comment we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our April 26, 2023 letter. Form 8-K filed on February 7, 2023 Reconciliation of Income Tax Expense from Continuing Operations to Adjusted Income Tax Expense from Continuing Operations, page 14 1.We note your response to our comment number 6. Given that the Other income tax adjustment items are arrived at by calculating the difference between the projected annual Non-GAAP income tax rate applied to the respective quarter’s pretax income and the actual tax rate computed for the respective quarters during the year under ASC 740- 270; please tell us how you considered whether the Non GAAP measure substitutes an individually tailored recognition and measurement method for those of GAAP which results in a misleading non-GAAP measure that violates Rule 100(b) of Regulation G. Please refer to Question 100.04 of the Compliance and Disclosure Interpretations on Non-
FirstName LastNameKevin Berryman Comapany NameJACOBS SOLUTIONS INC. June 2, 2023 Page 2 FirstName LastName Kevin Berryman JACOBS SOLUTIONS INC. June 2, 2023 Page 2 GAAP Financial Measures for guidance. You may contact Ameen Hamady at 202-551-3891 or in his absence, Shannon Menjivar at 202-551-3856 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
June 2, 2023
Kevin Berryman
Chief Financial Officer
JACOBS SOLUTIONS INC.
1999 Bryan Street Suite 1200
Dallas, Texas 75201
Re:JACOBS SOLUTIONS INC.
Form 10-K for the year ended September 30, 2022
Filed on November 21, 2022
Form 8-K filed on February 7, 2023
File No. 001-07463
Dear Kevin Berryman:
We have reviewed your May 26, 2023 response to our comment letter and have the
following comment. In our comment we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
April 26, 2023 letter.
Form 8-K filed on February 7, 2023
Reconciliation of Income Tax Expense from Continuing Operations to Adjusted Income Tax
Expense from Continuing Operations, page 14
1.We note your response to our comment number 6. Given that the Other income tax
adjustment items are arrived at by calculating the difference between the projected annual
Non-GAAP income tax rate applied to the respective quarter’s pretax income and the
actual tax rate computed for the respective quarters during the year under ASC 740-
270; please tell us how you considered whether the Non GAAP measure substitutes an
individually tailored recognition and measurement method for those of GAAP which
results in a misleading non-GAAP measure that violates Rule 100(b) of Regulation G.
Please refer to Question 100.04 of the Compliance and Disclosure Interpretations on Non-
FirstName LastNameKevin Berryman
Comapany NameJACOBS SOLUTIONS INC.
June 2, 2023 Page 2
FirstName LastName
Kevin Berryman
JACOBS SOLUTIONS INC.
June 2, 2023
Page 2
GAAP Financial Measures for guidance.
You may contact Ameen Hamady at 202-551-3891 or in his absence, Shannon
Menjivar at 202-551-3856 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction