SEC Comment Letter for BIO-TECHNE Corp (TECH) (CIK 0000842023) (TECH) — Mar 17, 2021
BIO-TECHNE Corp (TECH) (CIK 0000842023)
Date: March 17, 2021 · CIK: 0000842023 · Accession: 0000000000-21-003178
AI Filing Summary & Sentiment
File numbers found in text: 000-17272
Letter
United States securities and exchange commission logo March 17, 2021 James Hippel Chief Financial Officer Bio-Techne Corporation 614 McKinley Place N.E. Minneapolis, MN 55413 Re:Bio-Techne Corporation Form 10-K for the Fiscal Year Ended June 30, 2020 Filed August 26, 2020 Form 10-Q for the Quarterly Period Ended December 31, 2020 Filed February 8, 2021 File No. 000-17272 Dear Mr. Hippel: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarterly Period Ended December 31, 2020 Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations Net Earnings, page 21 1.Refer to your non-GAAP adjusted tax rate reconciliation on page 22. Your reported GAAP tax rate for the quarter and six months ended December 31, 2020, does not appear to reconcile to the rates disclosed in your discussion of income taxes on page 21. In future filings, please revise your disclosures to reconcile to your tax rate on a GAAP basis and present all significant reconciling items separately. In this regard, clarify why you re-cast your first quarter results using your effective tax rate for the first six months of fiscal 2021 and explain how this impacted your non-GAAP adjusted tax rate.
FirstName LastNameJames Hippel Comapany NameBio-Techne Corporation March 17, 2021 Page 2 FirstName LastName James Hippel Bio-Techne Corporation March 17, 2021 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. You may contact David Burton at (202) 551-3626 or Eric Atallah, Senior Accountant, at (202) 551-3663 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
March 17, 2021
James Hippel
Chief Financial Officer
Bio-Techne Corporation
614 McKinley Place N.E.
Minneapolis, MN 55413
Re:Bio-Techne Corporation
Form 10-K for the Fiscal Year Ended June 30, 2020
Filed August 26, 2020
Form 10-Q for the Quarterly Period Ended December 31, 2020
Filed February 8, 2021
File No. 000-17272
Dear Mr. Hippel:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-Q for the Quarterly Period Ended December 31, 2020
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Net Earnings, page 21
1.Refer to your non-GAAP adjusted tax rate reconciliation on page 22. Your reported
GAAP tax rate for the quarter and six months ended December 31, 2020, does not appear
to reconcile to the rates disclosed in your discussion of income taxes on page 21. In future
filings, please revise your disclosures to reconcile to your tax rate on a GAAP basis and
present all significant reconciling items separately. In this regard, clarify why you re-cast
your first quarter results using your effective tax rate for the first six months of fiscal 2021
and explain how this impacted your non-GAAP adjusted tax rate.
FirstName LastNameJames Hippel
Comapany NameBio-Techne Corporation
March 17, 2021 Page 2
FirstName LastName
James Hippel
Bio-Techne Corporation
March 17, 2021
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.
You may contact David Burton at (202) 551-3626 or Eric Atallah, Senior Accountant, at
(202) 551-3663 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences