SEC Comment Letter 0000000000-24-002781 to TETRA TECH INC (TTEK) (CIK 0000831641) (TTEK)
TETRA TECH INC (TTEK) (CIK 0000831641)
Date: March 13, 2024 · CIK: 0000831641 · Accession: 0000000000-24-002781
AI Filing Summary & Sentiment
File numbers found in text: 000-19655
Letter
United States securities and exchange commission logo March 13, 2024 Steven Burdick Executive Vice President and Chief Financial Officer Tetra Tech, Inc. 3475 East Foothill Boulevard Pasadena, CA 91107 Re:Tetra Tech, Inc. Form 10-K for Fiscal Year Ended October 1, 2023 Form 8-K Furnished November 15, 2023 Response dated March 1, 2024 File No. 000-19655 Dear Steven Burdick: We have reviewed your March 1, 2024 response to our comment letter and have the following comment(s). 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 January 30, 2024 letter. Investor Presentation for Earnings Call Held on November 16, 2023 EBITDA Margin Trend on U.S. and International Reporting Basis Reconciliation Summary for EBITDA - IFRS and Net Service Revenue (NSR) 1.We note your response to prior comment 3. Please tell us:
•Whether you applied IFRS to all other accounting transactions that would factor into the determination of Adjusted IFRS EBITDA, •Why you believe GAAP net income is more directly comparable to an adjusted IFRS measure of profit than IFRS net income, and •How the presentation of Adjusted IFRS EBITDA complies with the guidance contained in Question 100.04 of the Staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameSteven Burdick Comapany NameTetra Tech, Inc. March 13, 2024 Page 2 FirstName LastName Steven Burdick Tetra Tech, Inc. March 13, 2024 Page 2
2.Please explain why you believe it is appropriate to exclude revenue generated from RPS from the calculation of Net Service Revenue (NSR) for purposes of determining Adjusted IFRS EBITDA as a percentage of adjusted NSR. Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 13, 2024
Steven Burdick
Executive Vice President and Chief Financial Officer
Tetra Tech, Inc.
3475 East Foothill Boulevard
Pasadena, CA 91107
Re:Tetra Tech, Inc.
Form 10-K for Fiscal Year Ended October 1, 2023
Form 8-K Furnished November 15, 2023
Response dated March 1, 2024
File No. 000-19655
Dear Steven Burdick:
We have reviewed your March 1, 2024 response to our comment letter and have the
following comment(s).
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 January 30, 2024
letter.
Investor Presentation for Earnings Call Held on November 16, 2023
EBITDA Margin Trend on U.S. and International Reporting Basis
Reconciliation Summary for EBITDA - IFRS and Net Service Revenue (NSR)
1.We note your response to prior comment 3. Please tell us:
•Whether you applied IFRS to all other accounting transactions that would factor into
the determination of Adjusted IFRS EBITDA,
•Why you believe GAAP net income is more directly comparable to an adjusted IFRS
measure of profit than IFRS net income, and
•How the presentation of Adjusted IFRS EBITDA complies with the guidance
contained in Question 100.04 of the Staff's Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures.
FirstName LastNameSteven Burdick
Comapany NameTetra Tech, Inc.
March 13, 2024 Page 2
FirstName LastName
Steven Burdick
Tetra Tech, Inc.
March 13, 2024
Page 2
2.Please explain why you believe it is appropriate to exclude revenue generated from RPS
from the calculation of Net Service Revenue (NSR) for purposes of determining Adjusted
IFRS EBITDA as a percentage of adjusted NSR.
Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services