SEC Comment Letter 0000000000-23-013982 to ITT INC. (ITT) (CIK 0000216228) (ITT)
ITT INC. (ITT) (CIK 0000216228)
Date: Dec. 21, 2023 · CIK: 0000216228 · Accession: 0000000000-23-013982
AI Filing Summary & Sentiment
File numbers found in text: 001-05672
Letter
United States securities and exchange commission logo December 21, 2023 Emmanuel Caprais Chief Financial Officer ITT Inc. 100 Washington Boulevard, 6 Floor Stamford, Connecticut 06902 Re:ITT Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Response dated December 8, 2023 File No. 001-05672 Dear Emmanuel Caprais: 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 14, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 1.We note your response to prior comment 1. However, we continue to believe that the total segment operating income and margin as well as total adjusted segment operating income and margin measures are non-GAAP measures that do not comply Question 100.01 of the non-GAAP C&DIs. Therefore, please revise to remove these measures from your periodic filings, Form 8-K earnings releases, and earnings presentations on your website.
FirstName LastNameEmmanuel Caprais Comapany NameITT Inc. December 21, 2023 Page 2 FirstName LastName Emmanuel Caprais ITT Inc. December 21, 2023 Page 2 Please contact Megan Akst at 202-551-3407 or Melissa Kindelan at 202-551-3564 with any questions. Sincerely, Division of Corporation Finance Office of Technology
Show Raw Text
United States securities and exchange commission logo
December 21, 2023
Emmanuel Caprais
Chief Financial Officer
ITT Inc.
100 Washington Boulevard, 6 Floor
Stamford, Connecticut 06902
Re:ITT Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Response dated December 8, 2023
File No. 001-05672
Dear Emmanuel Caprais:
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 14,
2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
25
1.We note your response to prior comment 1. However, we continue to believe that the total
segment operating income and margin as well as total adjusted segment operating income
and margin measures are non-GAAP measures that do not comply Question 100.01 of the
non-GAAP C&DIs. Therefore, please revise to remove these measures from your periodic
filings, Form 8-K earnings releases, and earnings presentations on your website.
FirstName LastNameEmmanuel Caprais
Comapany NameITT Inc.
December 21, 2023 Page 2
FirstName LastName
Emmanuel Caprais
ITT Inc.
December 21, 2023
Page 2
Please contact Megan Akst at 202-551-3407 or Melissa Kindelan at 202-551-3564 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology