Correspondence 0001193125-24-280082 from COHERENT CORP. (COHR) (CIK 0000820318) (COHR)
COHERENT CORP. (COHR) (CIK 0000820318)
Date: Dec. 17, 2024 · CIK: 0000820318 · Accession: 0001193125-24-280082
AI Filing Summary & Sentiment
File numbers found in text: 001-39375
Referenced dates: July 3, 2024, November 22, 2024, October 15, 2024
Letter
Via EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services Washington, D.C. 20549 Re: COHERENT CORP. Form 8-K Filed May 6, 2024 File No. 001-39375
Dear Ms. Salik and Mr. O’Brien:
We are providing this letter in response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated November 22, 2024 regarding the above referenced filings made by Coherent Corp. (the “Company”). Set forth below are the Staff’s comments and our responses.
Form 8-K Filed May 6, 2024
Exhibit 99.2, page 41
COMMENT No. 1:
We note your responses to prior comments 1 and 2 from our letter dated July 3, 2024 and comment 2 from our letter dated October 15, 2024 related to your non-GAAP adjustments for integration, site consolidation and other costs. As inventory write- offs, overlapping labor and travel costs, and manufacturing inefficiencies related to sites being shut down appear to be normal, recurring operating expenses necessary to operate your business, please remove the adjustments for these expenses from your non-GAAP measures. Refer to Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures.
RESPONSE:
The Company respectfully acknowledges the Staff’s comment and hereby confirms that beginning with the quarter ending December 31, 2024, we will no longer include adjustments for inventory write-offs, overlapping labor and travel costs, and manufacturing inefficiencies related to sites being shut down in our non-GAAP measures in future filings and disclosures. Finally, we would like to confirm to the Staff that in future filings and other disclosures, we will recast our presentation of prior period non-GAAP measures to reflect the current period presentation (which reflects the changes described above and discussed with the Staff) to maintain comparability between periods.
Coherent Corp.
375 Saxonburg Blvd.
Saxonburg, PA 16056-9499
USA
Thank you for your consideration. If you have any additional questions regarding this response letter, please contact me at Sherri.Luther@coherent.com or Ilaria Mocciaro at Ilaria.Mocciaro@coherent.com at your earliest convenience.
Sincerely,
COHERENT CORP.
Show Raw Text
CORRESP 1 filename1.htm CORRESP Coherent Corp. 375 Saxonburg Blvd. Saxonburg, PA 16056-9499 USA Via EDGAR December 17, 2024 Ms. Nudrat Salik and Mr. Terence O’Brien Securities and Exchange Commission Division of Corporation Finance Office of Industrial Applications and Services 100 F Street, N.E. Washington, D.C. 20549 Re: COHERENT CORP. Form 8-K Filed May 6, 2024 File No. 001-39375 Dear Ms. Salik and Mr. O’Brien: We are providing this letter in response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated November 22, 2024 regarding the above referenced filings made by Coherent Corp. (the “Company”). Set forth below are the Staff’s comments and our responses. Form 8-K Filed May 6, 2024 Exhibit 99.2, page 41 COMMENT No. 1: We note your responses to prior comments 1 and 2 from our letter dated July 3, 2024 and comment 2 from our letter dated October 15, 2024 related to your non-GAAP adjustments for integration, site consolidation and other costs. As inventory write- offs, overlapping labor and travel costs, and manufacturing inefficiencies related to sites being shut down appear to be normal, recurring operating expenses necessary to operate your business, please remove the adjustments for these expenses from your non-GAAP measures. Refer to Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures. RESPONSE: The Company respectfully acknowledges the Staff’s comment and hereby confirms that beginning with the quarter ending December 31, 2024, we will no longer include adjustments for inventory write-offs, overlapping labor and travel costs, and manufacturing inefficiencies related to sites being shut down in our non-GAAP measures in future filings and disclosures. Finally, we would like to confirm to the Staff that in future filings and other disclosures, we will recast our presentation of prior period non-GAAP measures to reflect the current period presentation (which reflects the changes described above and discussed with the Staff) to maintain comparability between periods. Coherent Corp. 375 Saxonburg Blvd. Saxonburg, PA 16056-9499 USA Thank you for your consideration. If you have any additional questions regarding this response letter, please contact me at Sherri.Luther@coherent.com or Ilaria Mocciaro at Ilaria.Mocciaro@coherent.com at your earliest convenience. Sincerely, COHERENT CORP. /s/ Sherri Luther Sherri Luther Chief Financial Officer and Treasurer