SEC Comment Letter for ESCO TECHNOLOGIES INC (ESE) (CIK 0000866706) (ESE) — Feb 17, 2017
ESCO TECHNOLOGIES INC (ESE) (CIK 0000866706)
Date: Feb. 17, 2017 · CIK: 0000866706 · Accession: 0000000000-17-005706
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3720 February 17, 2017 Gary E. Muenster Chief Financial Officer Esco Technologies , Inc. 9900A Clayton Road St. Louis, Missouri
Re: Esco Tech nologies , Inc. Form 10 -K for Fiscal Year Ended September 30, 2016 Filed November 29, 2016 Form 8-K Filed on February 7 , 2017 File No. 001 -10596
Dear Mr. Muenster :
We have reviewed your filing and have the following comment . Please co mply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply.
Please respond to this comment within ten busine ss days by providing the requested information or advis e 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 8 -K filed February 7, 2017
Exhibit 99.1 Earnings Release 1. We note that in your “Earnings Summary” you omit the comparable GAAP measure for Q1 2017 EBITDA, a Non -GAAP measure, which is inconsistent with Question 102.10 of the updated Compliance and Disclosure Interpretation Guidance issu ed on May 17, 2016. Please comply with this comment in your next earnings release.
Gary E. Muenster Esco Technologies, Inc. February 17, 2017 Page 2
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 Joseph Cascarano, Senior Staff Accounta nt, at (202) 551 -3376 or Ivette Leon , Assistant Chief Accountant, at (202) 551 -3351 or me at (202) 551 -3810 with any questions.
Sincerely,
/s/ Carlos Pacho
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Mail Stop 3720 February 17, 2017 Gary E. Muenster Chief Financial Officer Esco Technologies , Inc. 9900A Clayton Road St. Louis, Missouri Re: Esco Tech nologies , Inc. Form 10 -K for Fiscal Year Ended September 30, 2016 Filed November 29, 2016 Form 8-K Filed on February 7 , 2017 File No. 001 -10596 Dear Mr. Muenster : We have reviewed your filing and have the following comment . Please co mply with the following comment in future filings. Confirm in writing that you will do so and explain to us how you intend to comply. Please respond to this comment within ten busine ss days by providing the requested information or advis e 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 8 -K filed February 7, 2017 Exhibit 99.1 Earnings Release 1. We note that in your “Earnings Summary” you omit the comparable GAAP measure for Q1 2017 EBITDA, a Non -GAAP measure, which is inconsistent with Question 102.10 of the updated Compliance and Disclosure Interpretation Guidance issu ed on May 17, 2016. Please comply with this comment in your next earnings release. Gary E. Muenster Esco Technologies, Inc. February 17, 2017 Page 2 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 Joseph Cascarano, Senior Staff Accounta nt, at (202) 551 -3376 or Ivette Leon , Assistant Chief Accountant, at (202) 551 -3351 or me at (202) 551 -3810 with any questions. Sincerely, /s/ Carlos Pacho Carlos Pacho Senior Assistant Chief Accountant AD Office 11 – Telecommunications