SEC Comment Letter 0000000000-23-013843 to STANLEY BLACK & DECKER, INC. (SWK) (CIK 0000093556) (SWK)
STANLEY BLACK & DECKER, INC. (SWK) (CIK 0000093556)
Date: Dec. 19, 2023 · CIK: 0000093556 · Accession: 0000000000-23-013843
AI Filing Summary & Sentiment
File numbers found in text: 001-05224
Letter
United States securities and exchange commission logo December 19, 2023 Patrick Hallinan Executive Vice President and Chief Financial Officer Stanley Black & Decker, Inc. 1000 Stanley Drive New Britain CT 06053 Re:Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 31, 2022 Form 8-K furnished October 27, 2023 Response dated December 8, 2023 File No. 001-05224 Dear Patrick Hallinan: We have reviewed your December 8, 2023 response to our comment letter and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our November 28, 2023 letter. Form 10-K for the Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Certain Items Impacting Earnings and Non-GAAP Financial Measures, page 31 1.We note your response to our prior comments 2 and 3. Please provide us further detail as to the amount and nature of the costs incurred that are part of your "supply chain transformation" adjustments in 2023. In this regard, it is not clear what is meant by "footprint rationalization actions" or "complexity reduction" and the type of costs that are included in these items. Also, please revise future filings to quantify the amount of the adjustments related to each type of activity. For example, related to the 2022 reconciliation, please disclose the amount related to integration related costs as well as the voluntary retirement program.
FirstName LastNamePatrick Hallinan Comapany NameStanley Black & Decker, Inc. December 19, 2023 Page 2 FirstName LastName Patrick Hallinan Stanley Black & Decker, Inc. December 19, 2023 Page 2 Please contact Claire Erlanger at 202-551-3301 or Melissa Gilmore at 202-551-3777 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
December 19, 2023
Patrick Hallinan
Executive Vice President and Chief Financial Officer
Stanley Black & Decker, Inc.
1000 Stanley Drive
New Britain CT 06053
Re:Stanley Black & Decker, Inc.
Form 10-K for the Year Ended December 31, 2022
Form 8-K furnished October 27, 2023
Response dated December 8, 2023
File No. 001-05224
Dear Patrick Hallinan:
We have reviewed your December 8, 2023 response to our comment letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in our November 28, 2023
letter.
Form 10-K for the Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Certain Items Impacting Earnings and Non-GAAP Financial Measures, page 31
1.We note your response to our prior comments 2 and 3. Please provide us further detail as
to the amount and nature of the costs incurred that are part of your "supply chain
transformation" adjustments in 2023. In this regard, it is not clear what is meant by
"footprint rationalization actions" or "complexity reduction" and the type of costs that are
included in these items. Also, please revise future filings to quantify the amount of the
adjustments related to each type of activity. For example, related to the 2022
reconciliation, please disclose the amount related to integration related costs as well as the
voluntary retirement program.
FirstName LastNamePatrick Hallinan
Comapany NameStanley Black & Decker, Inc.
December 19, 2023 Page 2
FirstName LastName
Patrick Hallinan
Stanley Black & Decker, Inc.
December 19, 2023
Page 2
Please contact Claire Erlanger at 202-551-3301 or Melissa Gilmore at 202-551-3777 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing