SEC Comment Letter 0000000000-23-001093 to BIO-TECHNE Corp (TECH) (CIK 0000842023) (TECH)
BIO-TECHNE Corp (TECH) (CIK 0000842023)
Date: Feb. 2, 2023 · CIK: 0000842023 · Accession: 0000000000-23-001093
AI Filing Summary & Sentiment
File numbers found in text: 000-17272
Letter
United States securities and exchange commission logo February 2, 2023 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, 2022 Filed August 24, 2022 File Number 000-17272 Dear James 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 the 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 the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended June 30, 2022 Notes to Consolidated Financial Statements Note 1. Description of Business and Summary of Significant Accounting Policies Investments , page 55 1.We note that in December 2021, you paid $25 million to enter into a forward contract that would require you to invest in and subsequently acquire Wilson Wolf Corporation in the event that certain revenue or EBITDA thresholds are met. We also note that you have accounted for this payment as a cost basis equity investment pursuant to the measurement alternative outlined in ASC 321-10-35-2. Please provide us with a detailed analysis explaining how you determined that this transaction should not be accounted for as a derivative under ASC 815.
FirstName LastNameJames Hippel Comapany NameBio-Techne Corporation February 2, 2023 Page 2 FirstName LastName James Hippel Bio-Techne Corporation February 2, 2023 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 Mary Mast at 202-551-3613 or Angela Connell at 202-551-3426 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
Show Raw Text
United States securities and exchange commission logo
February 2, 2023
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, 2022
Filed August 24, 2022
File Number 000-17272
Dear James 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 the 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 the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended June 30, 2022
Notes to Consolidated Financial Statements
Note 1. Description of Business and Summary of Significant Accounting Policies
Investments , page 55
1.We note that in December 2021, you paid $25 million to enter into a forward contract that
would require you to invest in and subsequently acquire Wilson Wolf Corporation in the
event that certain revenue or EBITDA thresholds are met. We also note that you have
accounted for this payment as a cost basis equity investment pursuant to the measurement
alternative outlined in ASC 321-10-35-2. Please provide us with a detailed analysis
explaining how you determined that this transaction should not be accounted for as a
derivative under ASC 815.
FirstName LastNameJames Hippel
Comapany NameBio-Techne Corporation
February 2, 2023 Page 2
FirstName LastName
James Hippel
Bio-Techne Corporation
February 2, 2023
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 Mary Mast at 202-551-3613 or Angela Connell at 202-551-3426 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences