SEC Comment Letter 0000000000-24-001502 to NORDSON CORP (NDSN) (CIK 0000072331) (NDSN)
NORDSON CORP (NDSN) (CIK 0000072331)
Date: Feb. 7, 2024 · CIK: 0000072331 · Accession: 0000000000-24-001502
AI Filing Summary & Sentiment
File numbers found in text: 000-07977
Letter
United States securities and exchange commission logo February 7, 2024 Stephen Shamrock Interim Chief Financial Officer Nordson Corporation 28601 Clemens Road Westlake, OH 44145 Re:Nordson Corporation Form 10-K for the Fiscal Year Ended October 31, 2023 Form 8-K Filed December 13, 2023 File No. 000-07977 Dear Stephen Shamrock: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. 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 8-K filed December 13, 2023 Exhibit 99.1 Outlook, page 2 1.We note on page 2 of your earnings release you provide outlook guidance for the non- GAAP financial measure adjusted diluted earnings per share without providing a reconciliation to the most directly comparable GAAP financial measure. Refer to Question 102.10(b) of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures updated December 13, 2022 and provide in the future a reconciliation or the required information. Reconciliation of Non-GAAP Measures - Profitability, page 9 2.We note your reconciliations of non-GAAP measures. Please consider clearly labeling each measure as non-GAAP rather than including GAAP labeled line items under the caption "Non-GAAP Measures - Adjusted Profitability" so that the intent of this disclosure is clear. Similarly, consider clearly labeling "adjusted EPS" and "revised
FirstName LastNameStephen Shamrock Comapany NameNordson Corporation February 7, 2024 Page 2 FirstName LastName Stephen Shamrock Nordson Corporation February 7, 2024 Page 2 adjusted EPS" as non-GAAP. 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. Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-551- 3361 with any questions. Sincerely, Division of Corporation Finance Office of Technology
Show Raw Text
United States securities and exchange commission logo
February 7, 2024
Stephen Shamrock
Interim Chief Financial Officer
Nordson Corporation
28601 Clemens Road
Westlake, OH 44145
Re:Nordson Corporation
Form 10-K for the Fiscal Year Ended October 31, 2023
Form 8-K Filed December 13, 2023
File No. 000-07977
Dear Stephen Shamrock:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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 8-K filed December 13, 2023
Exhibit 99.1
Outlook, page 2
1.We note on page 2 of your earnings release you provide outlook guidance for the non-
GAAP financial measure adjusted diluted earnings per share without providing a
reconciliation to the most directly comparable GAAP financial measure. Refer to
Question 102.10(b) of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures updated December 13, 2022 and provide in the future a reconciliation
or the required information.
Reconciliation of Non-GAAP Measures - Profitability, page 9
2.We note your reconciliations of non-GAAP measures. Please consider clearly labeling
each measure as non-GAAP rather than including GAAP labeled line items under the
caption "Non-GAAP Measures - Adjusted Profitability" so that the intent of this
disclosure is clear. Similarly, consider clearly labeling "adjusted EPS" and "revised
FirstName LastNameStephen Shamrock
Comapany NameNordson Corporation
February 7, 2024 Page 2
FirstName LastName
Stephen Shamrock
Nordson Corporation
February 7, 2024
Page 2
adjusted EPS" as non-GAAP.
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.
Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-551-
3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology