SEC Comment Letter 0000000000-22-013463 to MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968) (MHK)
MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968)
Date: Dec. 14, 2022 · CIK: 0000851968 · Accession: 0000000000-22-013463
AI Filing Summary & Sentiment
File numbers found in text: 001-13697
Letter
United States securities and exchange commission logo December 14, 2022 James F. Brunk Chief Financial Officer Mohawk Industries, Inc. 160 S. Industrial Blvd. Calhoun, GA 30701 Re:Mohawk Industries, Inc. Form 10-K for the Year Ended December 31, 2021 Filed February 23, 2022 Form 8-K Filed October 27, 2022 File No. 001-13697 Dear James F. Brunk: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2021 Item 8. Consolidated Financial Statements and Supplementary Data (10) Long-Term Debt, page 64 1.We note your credit facilities include certain affirmative and negative covenants that impose restrictions on your financial and business operations. For each class of debt, please tell us whether you were in compliance with the covenants as of the reporting date. Form 8-K Filed October 27, 2022 Exhibit 99.1, page 1 2.We note that you have reconciled EBITDA and Adjusted EBITDA to operating income (loss). Question 103.01 of the updated Non-GAAP Compliance and Disclosure
FirstName LastNameJames F. Brunk Comapany NameMohawk Industries, Inc. December 14, 2022 Page 2 FirstName LastName James F. Brunk Mohawk Industries, Inc. December 14, 2022 Page 2 Interpretations issued on April 4, 2018 states EBITDA is defined as "earnings before interest, taxes, depreciation and amortization," with earnings intended to mean net income rather than operating income. In future filings, please reconcile EBITDA and Adjusted EBITA to net (loss) earnings including noncontrolling interests. 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 Jeffrey Gordon at 202-551-3866 or Jean Yu at 202-551-3305 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
December 14, 2022
James F. Brunk
Chief Financial Officer
Mohawk Industries, Inc.
160 S. Industrial Blvd.
Calhoun, GA 30701
Re:Mohawk Industries, Inc.
Form 10-K for the Year Ended December 31, 2021
Filed February 23, 2022
Form 8-K Filed October 27, 2022
File No. 001-13697
Dear James F. Brunk:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2021
Item 8. Consolidated Financial Statements and Supplementary Data
(10) Long-Term Debt, page 64
1.We note your credit facilities include certain affirmative and negative covenants that
impose restrictions on your financial and business operations. For each class of debt,
please tell us whether you were in compliance with the covenants as of the reporting
date.
Form 8-K Filed October 27, 2022
Exhibit 99.1, page 1
2.We note that you have reconciled EBITDA and Adjusted EBITDA to operating income
(loss). Question 103.01 of the updated Non-GAAP Compliance and Disclosure
FirstName LastNameJames F. Brunk
Comapany NameMohawk Industries, Inc.
December 14, 2022 Page 2
FirstName LastName
James F. Brunk
Mohawk Industries, Inc.
December 14, 2022
Page 2
Interpretations issued on April 4, 2018 states EBITDA is defined as "earnings before
interest, taxes, depreciation and amortization," with earnings intended to mean net income
rather than operating income. In future filings, please reconcile EBITDA and Adjusted
EBITA to net (loss) earnings including noncontrolling interests.
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 Jeffrey Gordon at 202-551-3866 or Jean Yu at 202-551-3305 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing