SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 24, 2026

Christopher Tucker
Chief Financial Officer
ESCO TECHNOLOGIES INC
645 Maryville Centre Drive, Suite 300
St. Louis , MO 63141

 Re: ESCO TECHNOLOGIES INC
 Form 10-K for the Fiscal Year Ended September 30, 2025
 Filed December 1, 2025
 File No. 001-10596
Dear Christopher Tucker:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 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.

Form 10-K for the Fiscal Year Ended September 30, 2025
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Estimates
Goodwill and Other Long-Lived Assets, page 27

1. We note the disclosure in your financial statement footnotes that you
performed a
 quantitative impairment analysis related to certain reporting units and
a qualitative
 impairment analysis related to other reporting units and concluded no
goodwill was
 impaired. Given the significance of your goodwill balance, please revise
your Critical
 Accounting Estimates in future filings to clarify whether any of your
reporting units are
 at risk of failing the goodwill impairment test. A reporting unit is at
risk of failing the
 impairment test if it has a fair value that is not substantially in
excess of carrying value.
 If no reporting units are at risk based on your most recent impairment
test, please
 disclose such information to your readers as we believe it provides them
with valuable
 information in assessing the sensitivity of your goodwill to future
impairment.
 Alternatively, if a reporting unit is at risk of failing the impairment
test and a material
 impairment charge could occur, please disclose the following:
 February 24, 2026
Page 2

 The percentage by which fair value exceeded carrying value as of
the date of the
 most recent test;
 The amount of goodwill allocated to the reporting unit;
 A description of the methods and key assumptions used and how the
key
 assumptions were determined;
 A discussion of the degree of uncertainty associated with the key
assumptions. The
 discussion regarding uncertainty should provide specifics to the
extent possible (e.g.,
 the valuation model assumes recovery from a business downturn within
a defined
 period of time); and
 A description of potential events and/or changes in circumstances
that could
 reasonably be expected to negatively affect the key assumptions.
 Please show us your proposed revision in your response. Refer to Item
303(b)(3) of
 Regulation S-K and Section V of SEC Release No. 33-8350 for guidance.

Financial Statements for the Fiscal Year Ended September 30, 2025
Notes to Consolidated Financial Statements
Note 10. Business Segment Information, page F-28

2. We note that your tabular disclosures of segment information beginning
on page F-29
 include separate columns for each of the reportable segments, a subtotal
column for the
 reportable segments titled Segment Total, as well as a column for
Corporate which is
 added to arrive at a Total column. It does not appear that your
Corporate column
 qualifies as an operating and reportable segment under ASC 280. As such,
the current
 disclosure appears to result in the presentation of certain amounts that
are not required by
 ASC 280. Please revise your footnote as follows:
 Reconcile the total of the reportable segments measures of
segment profit or loss to
 consolidated income before taxes as required by ASC 280-10-50-30(b).
Similarly,
 revise to reconcile other totals of reportable segments amounts,
such as revenues,
 assets, and depreciation and amortization, to the corresponding
consolidated amounts
 as required by ASC 280-10-50-30.
 Include amounts attributable to Corporate separately from other
reconciling items
 when reconciling from total reportable segment amounts to
consolidated amounts,
 rather than as currently presented in a separate column. See ASC
280-10-50-15 and
 ASC 280-10-50-31. See also ASC 280-10-55-48; and
 Ensure your resulting disclosure does not present consolidated EBIT
as currently
 reflected in the Total column.
 Please show us your proposed revision in your response, or explain to us
why no revision
 is needed to comply with ASC 280.

 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.
 February 24, 2026
Page 3

 Please contact SiSi Cheng at 202-551-5004 or Jennifer Thompson at
202-551-3737 with
any questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
</TEXT>
</DOCUMENT>