UPLOAD Filing
SHERWIN WILLIAMS CO
Date: June 18, 2025 · CIK: 0000089800 · Accession: 0000000000-25-006438
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-04851
Letter
Re: Sherwin-Williams Company Form 10-K for Fiscal Year Ended December 31, 2024 File No. 001-04851 Dear Allen Mistysyn:
June 18, 2025
Allen Mistysyn Senior Vice President Finance and Chief Financial Officer Sherwin-Williams Company 101 West Prospect Avenue Cleveland OH 44115
We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s).
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 Fiscal Year Ended December 31, 2024 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Summary, page 24
1. We note you disclose Adjusted EBITDA within your summary bullet points. When presenting non-GAAP measures, please present the most directly comparable GAAP measure with equal or greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Please make similar revisions to your press releases furnished under Item 2.02 of Form 8-K when presenting your non-GAAP measures in the summary section of your releases. Notes to the Consolidated Financial Statements Note 22 - Reportable Segment Information, page 90
2. Please tell us how your disclosure complies with the requirement to disclose how the chief operating decision maker uses your reported measure of segment profit or June 18, 2025 Page 2
loss in assessing segment performance and deciding how to allocate resources pursuant to ASC 280-10-50-29.f. Refer to ASC 280-10-55-47.bb for guidance. 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 Patrick Kuhn at 202-551-3308 or Abe Friedman at 202-551-8298 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
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<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> June 18, 2025 Allen Mistysyn Senior Vice President Finance and Chief Financial Officer Sherwin-Williams Company 101 West Prospect Avenue Cleveland OH 44115 Re: Sherwin-Williams Company Form 10-K for Fiscal Year Ended December 31, 2024 File No. 001-04851 Dear Allen Mistysyn: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). 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 Fiscal Year Ended December 31, 2024 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Summary, page 24 1. We note you disclose Adjusted EBITDA within your summary bullet points. When presenting non-GAAP measures, please present the most directly comparable GAAP measure with equal or greater prominence. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Please make similar revisions to your press releases furnished under Item 2.02 of Form 8-K when presenting your non-GAAP measures in the summary section of your releases. Notes to the Consolidated Financial Statements Note 22 - Reportable Segment Information, page 90 2. Please tell us how your disclosure complies with the requirement to disclose how the chief operating decision maker uses your reported measure of segment profit or June 18, 2025 Page 2 loss in assessing segment performance and deciding how to allocate resources pursuant to ASC 280-10-50-29.f. Refer to ASC 280-10-55-47.bb for guidance. 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 Patrick Kuhn at 202-551-3308 or Abe Friedman at 202-551-8298 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services </TEXT> </DOCUMENT>