SEC Comment Letter 0000000000-23-013522 to Envela Corp (ELA) (CIK 0000701719) (ELA)
Envela Corp (ELA) (CIK 0000701719)
Date: Dec. 12, 2023 · CIK: 0000701719 · Accession: 0000000000-23-013522
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File numbers found in text: 001-11048
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United States securities and exchange commission logo
December 12, 2023
Bret A. Pedersen
Chief Financial Officer
Envela Corporation
1901 Gateway Drive , Ste 100 .
Irving, TX 75038
Re:Envela Corporation
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 001-11048
Dear Bret A. Pedersen:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
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, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Use of Non-U.S. GAAP Financial Measures, page 19
1.As your measure of "EBITDA" is adjusted for additional items other than interest, taxes
and depreciation and amortization, please revise your disclosure to retitle this measure.
Please see Question 103.01 of the Staff’s Compliance and Disclosure Interpretations on
Non-GAAP Financial Measures for further guidance.
Results of Operations, page 21
2.Please quantify, discuss, and analyze changes in costs of good sold for each segment on a
stand-alone basis in addition to your current discussion on gross profit. Additionally,
please quantify and discuss the significant components of costs of goods sold to the extent
material. See Item 303 of Regulation S-K.
FirstName LastNameBret A. Pedersen
Comapany NameEnvela Corporation
December 12, 2023 Page 2
FirstName LastName
Bret A. Pedersen
Envela Corporation
December 12, 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.
Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-3307
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services