SEC Comment Letter 0000000000-24-000406 to RPM INTERNATIONAL INC/DE/ (RPM) (CIK 0000110621) (RPM)
RPM INTERNATIONAL INC/DE/ (RPM) (CIK 0000110621)
Date: Jan. 11, 2024 · CIK: 0000110621 · Accession: 0000000000-24-000406
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo January 11, 2024 Edward Moore Senior Vice President RPM INTERNATIONAL INC/DE/ 2628 Pearl Road , P.O. Box 777 Medina, Ohio 44258 Re:RPM INTERNATIONAL INC/DE/ Form 8-K filed July 25, 2023 File No. 1-14187 Dear Edward Moore: We have reviewed your filing 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. After reviewing your response to this letter, we may have additional comments. Form 8-K filed July 25, 2023 Exhibit 99.1, page 10 1.Given the materiality of the MAP initiatives adjustment to your consolidated Adjusted EBIT measure, please expand Note (d) to quantify the material components. 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 Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355 if you have questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
January 11, 2024
Edward Moore
Senior Vice President
RPM INTERNATIONAL INC/DE/
2628 Pearl Road , P.O. Box 777
Medina, Ohio 44258
Re:RPM INTERNATIONAL INC/DE/
Form 8-K filed July 25, 2023
File No. 1-14187
Dear Edward Moore:
We have reviewed your filing 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. After reviewing your response to this letter, we may have
additional comments.
Form 8-K filed July 25, 2023
Exhibit 99.1, page 10
1.Given the materiality of the MAP initiatives adjustment to your consolidated Adjusted
EBIT measure, please expand Note (d) to quantify the material components.
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 Al Pavot at 202-551-3738 or Terence O'Brien at 202-551-3355
if you have questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services