SEC Comment Letter 0000000000-23-012343 to MIDDLEBY Corp (MIDD) (CIK 0000769520) (MIDD)
MIDDLEBY Corp (MIDD) (CIK 0000769520)
Date: Nov. 10, 2023 · CIK: 0000769520 · Accession: 0000000000-23-012343
AI Filing Summary & Sentiment
File numbers found in text: 001-09973
Letter
United States securities and exchange commission logo November 9, 2023 Bryan Mittelman Chief Financial Officer The Middleby Corporation 1400 Toastmaster Drive Elgin, IL 60120 Re:The Middleby Corporation Form 10-K For Fiscal Year Ended December 31, 2022 Response Dated October 26, 2023 File No. 001-09973 Dear Bryan Mittelman: We have reviewed your October 26, 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 October 13, 2023 letter. Response dated October 26, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 1.Your response to the first item of prior comment 1 reiterates information provided in your initial response, dated October 6, 2023, and continues to include a materiality qualification. Accordingly, we reissue this portion of our comment. Explain to us how you considered providing specific disclosure regarding the climate-related changes and opportunities identified in our prior comment, and tell us how you assessed materiality. Your response should discuss the climate-related changes in demand and competition you have experienced, and explain how you determined there were not material for purposes of disclosure, taking into account your statements that "action on climate change is an area of focus for our industry" and you expect "additional future opportunities to develop and sell sustainable products."
FirstName LastNameBryan Mittelman Comapany NameThe Middleby Corporation November 9, 2023 Page 2 FirstName LastName Bryan Mittelman The Middleby Corporation November 9, 2023 Page 2 Please contact Charli Gibbs-Tabler at 202-551-6388 or Jennifer Angelini at 202-551- 3047 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Bryan Mittleman
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United States securities and exchange commission logo
November 9, 2023
Bryan Mittelman
Chief Financial Officer
The Middleby Corporation
1400 Toastmaster Drive
Elgin, IL 60120
Re:The Middleby Corporation
Form 10-K For Fiscal Year Ended December 31, 2022
Response Dated October 26, 2023
File No. 001-09973
Dear Bryan Mittelman:
We have reviewed your October 26, 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 October 13, 2023
letter.
Response dated October 26, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
27
1.Your response to the first item of prior comment 1 reiterates information provided in your
initial response, dated October 6, 2023, and continues to include a materiality
qualification. Accordingly, we reissue this portion of our comment. Explain to us how you
considered providing specific disclosure regarding the climate-related changes and
opportunities identified in our prior comment, and tell us how you assessed materiality.
Your response should discuss the climate-related changes in demand and competition you
have experienced, and explain how you determined there were not material for purposes
of disclosure, taking into account your statements that "action on climate change is an area
of focus for our industry" and you expect "additional future opportunities to develop and
sell sustainable products."
FirstName LastNameBryan Mittelman
Comapany NameThe Middleby Corporation
November 9, 2023 Page 2
FirstName LastName
Bryan Mittelman
The Middleby Corporation
November 9, 2023
Page 2
Please contact Charli Gibbs-Tabler at 202-551-6388 or Jennifer Angelini at 202-551-
3047 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Bryan Mittleman