SEC Comment Letter 0000000000-23-003257 to SMITH A O CORP (AOS) (CIK 0000091142) (AOS)
SMITH A O CORP (AOS) (CIK 0000091142)
Date: March 31, 2023 · CIK: 0000091142 · Accession: 0000000000-23-003257
AI Filing Summary & Sentiment
File numbers found in text: 001-00475
Letter
United States securities and exchange commission logo March 31, 2023 Charles Lauber Chief Financial Officer A. O. Smith Corporation 11270 West Park Place Milwaukee, Wisconsin 53224-9508 Re:A. O. Smith Corporation Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 14, 2023 File No. 001-00475 Dear Charles Lauber: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 apply 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 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Measures, page 24 1.We note that you present Total Segment Earnings as a GAAP measure. Please note the presentation of a total segment profit or loss measure in any context other than the ASC 280 required reconciliation in the financial statement footnotes is considered a presentation of a non-GAAP measure. Furthermore, as a result, your Total Adjusted Segment Earnings non-GAAP measure currently is not reconciled to a GAAP measure. Show us how you will revise your presentation in future filings. Refer to Question 104.04 of the Compliance & Disclosure Interpretations for Non-GAAP Financial Measures.
FirstName LastNameCharles Lauber Comapany NameA. O. Smith Corporation March 31, 2023 Page 2 FirstName LastName Charles Lauber A. O. Smith Corporation March 31, 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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Andrew Blume, Senior Staff Accountant, at 202-551-3254 at with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
March 31, 2023
Charles Lauber
Chief Financial Officer
A. O. Smith Corporation
11270 West Park Place
Milwaukee, Wisconsin 53224-9508
Re:A. O. Smith Corporation
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 14, 2023
File No. 001-00475
Dear Charles Lauber:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
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 apply 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
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures, page 24
1.We note that you present Total Segment Earnings as a GAAP measure. Please note the
presentation of a total segment profit or loss measure in any context other than the ASC
280 required reconciliation in the financial statement footnotes is considered a
presentation of a non-GAAP measure. Furthermore, as a result, your Total Adjusted
Segment Earnings non-GAAP measure currently is not reconciled to a GAAP measure.
Show us how you will revise your presentation in future filings. Refer to Question 104.04
of the Compliance & Disclosure Interpretations for Non-GAAP Financial Measures.
FirstName LastNameCharles Lauber
Comapany NameA. O. Smith Corporation
March 31, 2023 Page 2
FirstName LastName
Charles Lauber
A. O. Smith Corporation
March 31, 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 Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Andrew
Blume, Senior Staff Accountant, at 202-551-3254 at with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing