SEC Comment Letter 0000000000-24-003986 to SCOTTS MIRACLE-GRO CO (SMG) (CIK 0000825542) (SMG)
SCOTTS MIRACLE-GRO CO (SMG) (CIK 0000825542)
Date: April 12, 2024 · CIK: 0000825542 · Accession: 0000000000-24-003986
AI Filing Summary & Sentiment
File numbers found in text: 001-11593
Letter
United States securities and exchange commission logo April 12, 2024 Matthew Garth Chief Financial Officer Scotts Miracle-Gro Co 14111 Scottslawn Road Marysville, Ohio 43041 Re:Scotts Miracle-Gro Co Form 10-K filed November 22, 2023 Form 8-K filed November 1, 2023 Response filed February 9, 2024 File No. 001-11593 Dear Matthew Garth: We have reviewed your February 9, 2024 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 the 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 January 26, 2024 letter. Form 10-K for the Year Ended September 30, 2023 Non-GAAP Measures, page 43 1.We note your response to prior comment 1. Notwithstanding their scope and magnitude, the inventory impairment charges recognized following the decision to discontinue and exit the market for the majority of your lighting brands and product lines do not appear to be outside the normal course of your operations. With reference to Question 100.01 of the Compliance and Disclosure Interpretations for Non-GAAP Financial Measures and ASC 420-10-S99-3, please confirm that you will no longer exclude these inventory impairments from your non-GAAP measures.
Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters.
FirstName LastNameMatthew Garth Comapany NameScotts Miracle-Gro Co April 12, 2024 Page 2 FirstName LastName Matthew Garth Scotts Miracle-Gro Co April 12, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
April 12, 2024
Matthew Garth
Chief Financial Officer
Scotts Miracle-Gro Co
14111 Scottslawn Road
Marysville, Ohio 43041
Re:Scotts Miracle-Gro Co
Form 10-K filed November 22, 2023
Form 8-K filed November 1, 2023
Response filed February 9, 2024
File No. 001-11593
Dear Matthew Garth:
We have reviewed your February 9, 2024 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
the 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 January 26,
2024 letter.
Form 10-K for the Year Ended September 30, 2023
Non-GAAP Measures, page 43
1.We note your response to prior comment 1. Notwithstanding their scope and magnitude,
the inventory impairment charges recognized following the decision to discontinue and
exit the market for the majority of your lighting brands and product lines do not appear to
be outside the normal course of your operations. With reference to Question 100.01 of the
Compliance and Disclosure Interpretations for Non-GAAP Financial Measures and ASC
420-10-S99-3, please confirm that you will no longer exclude these inventory
impairments from your non-GAAP measures.
Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters.
FirstName LastNameMatthew Garth
Comapany NameScotts Miracle-Gro Co
April 12, 2024 Page 2
FirstName LastName
Matthew Garth
Scotts Miracle-Gro Co
April 12, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services