SEC Comment Letter 0000000000-23-010153 to 3M CO (MMM) (CIK 0000066740) (MMM)
3M CO (MMM) (CIK 0000066740)
Date: Sept. 14, 2023 · CIK: 0000066740 · Accession: 0000000000-23-010153
AI Filing Summary & Sentiment
File numbers found in text: 001-03285
Letter
United States securities and exchange commission logo September 14, 2023 Monish Patolawala Chief Financial Officer 3M Company 3M Center St. Paul, Minnesota 55144 Re:3M Company Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 8, 2023 File No. 001-03285 Dear Monish Patolawala: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the Fiscal Year Ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Certain amounts adjusted for special items - (non-GAAP measures), page 22 1.We note in your Form 10-K for the year ended December 31, 2022, your Form 10-Q for the six months ended June 30, 2023 and your related earnings releases included on Form 8-K that your adjusted operating income/loss reconciliation includes significant adjustments for "Net costs for significant litigation." Please provide us the specific litigation costs included in the non-GAAP measures each period, including the amounts related to settlements, accruals and legal fees and provide additional disclosure of these amounts in future filings. In addition, explain to us and disclose in future filings how each component of the elimination is consistent with the guidance in Question 100.01 of the SEC's Compliance and Disclosure Interpretations for Non-GAAP measures.
FirstName LastNameMonish Patolawala Comapany Name3M Company September 14, 2023 Page 2 FirstName LastName Monish Patolawala 3M Company September 14, 2023 Page 2 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. You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio, Accounting Branch Chief, at (202) 551-3676 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
Show Raw Text
United States securities and exchange commission logo
September 14, 2023
Monish Patolawala
Chief Financial Officer
3M Company
3M Center
St. Paul, Minnesota 55144
Re:3M Company
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 8, 2023
File No. 001-03285
Dear Monish Patolawala:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Certain amounts adjusted for special items - (non-GAAP measures), page 22
1.We note in your Form 10-K for the year ended December 31, 2022, your Form 10-Q for
the six months ended June 30, 2023 and your related earnings releases included on Form
8-K that your adjusted operating income/loss reconciliation includes significant
adjustments for "Net costs for significant litigation." Please provide us the specific
litigation costs included in the non-GAAP measures each period, including the amounts
related to settlements, accruals and legal fees and provide additional disclosure of these
amounts in future filings. In addition, explain to us and disclose in future filings how each
component of the elimination is consistent with the guidance in Question 100.01 of the
SEC's Compliance and Disclosure Interpretations for Non-GAAP measures.
FirstName LastNameMonish Patolawala
Comapany Name3M Company
September 14, 2023 Page 2
FirstName LastName
Monish Patolawala
3M Company
September 14, 2023
Page 2
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.
You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio, Accounting
Branch Chief, at (202) 551-3676 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services