SEC Comment Letter 0000000000-23-003077 to SEABOARD CORP /DE/ (SEB) (CIK 0000088121) (SEB)
SEABOARD CORP /DE/ (SEB) (CIK 0000088121)
Date: March 28, 2023 · CIK: 0000088121 · Accession: 0000000000-23-003077
AI Filing Summary & Sentiment
File numbers found in text: 001-03390
Letter
United States securities and exchange commission logo March 28, 2023 David Rankin Chief Financial Officer Seaboard Corporation 9000 West 67th Street Merriam, KS 66202 Re:Seaboard Corporation Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 14, 2023 File No. 001-03390 Dear David Rankin: 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 Fiscal Year Ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 21 1.Throughout your results of operations year-to-year comparison, you identify multiple factors for changes in line items without quantifying the impact of each. For example, in the CT&M segment comparison you attribute the change in revenue to higher sales prices of commodities, and to a lesser extent, higher volumes to third-party customers, partially offset by lower volumes to affiliates due to timing of shipments. Please revise to quantify the change for each of the factors that you cite. Refer to Item 303(b) of Regulation S-K. 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 LastNameDavid Rankin Comapany NameSeaboard Corporation March 28, 2023 Page 2 FirstName LastName David Rankin Seaboard Corporation March 28, 2023 Page 2 You may contact Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 28, 2023
David Rankin
Chief Financial Officer
Seaboard Corporation
9000 West 67th Street
Merriam, KS 66202
Re:Seaboard Corporation
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 14, 2023
File No. 001-03390
Dear David Rankin:
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 Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 21
1.Throughout your results of operations year-to-year comparison, you identify multiple
factors for changes in line items without quantifying the impact of each. For example, in
the CT&M segment comparison you attribute the change in revenue to higher sales prices
of commodities, and to a lesser extent, higher volumes to third-party customers, partially
offset by lower volumes to affiliates due to timing of shipments. Please revise to quantify
the change for each of the factors that you cite. Refer to Item 303(b) of Regulation S-K.
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 LastNameDavid Rankin
Comapany NameSeaboard Corporation
March 28, 2023 Page 2
FirstName LastName
David Rankin
Seaboard Corporation
March 28, 2023
Page 2
You may contact Nasreen Mohammed at 202-551-3773 or Joel Parker at 202-551-3651
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services