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SEC Comment Letter for ESCO TECHNOLOGIES (ESE) — Mar 11, 2026

ESCO TECHNOLOGIES INC
Date: March 11, 2026 · CIK: 0000866706 · Accession: 0000000000-26-002474

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File numbers found in text: 001-10596

Date
March 11, 2026
Author
Finance
Form
UPLOAD
Company
ESCO TECHNOLOGIES INC

Letter

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:

March 11, 2026

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

We have reviewed your March 3, 2026 response to our comment letter and have the following comment.

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. Unless we note otherwise, any references to prior comments are to comments in our February 24, 2026 letter.

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

1. We note your response to prior comment 2, including your proposed reconciliation of segment assets to consolidated assets. Please tell us how you determined the line currently titled Corporate Assets contains no significant items that should be separately identified and described. For example, it appears almost half of Corporate Assets may consist of goodwill not allocated to segments, and other acquired intangible assets not allocated to segments may represent a significant portion of the remainder. See ASC 280-10-50-31 and 280-10-55-49 for guidance. March 11, 2026 Page 2

Please contact SiSi Cheng at 202-551-5004 or Jennifer Thompson at 202-551-3737 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of Corporation
Finance
Office of Manufacturing

Show Raw Text
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<TEXT>
 March 11, 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 reviewed your March 3, 2026 response to our comment letter and
have the
following comment.

 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. Unless
we note otherwise, any references to prior comments are to comments in our
February 24, 2026
letter.

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

1. We note your response to prior comment 2, including your proposed
reconciliation of
 segment assets to consolidated assets. Please tell us how you determined
the line
 currently titled Corporate Assets contains no significant items
that should be separately
 identified and described. For example, it appears almost half of
Corporate Assets may
 consist of goodwill not allocated to segments, and other acquired
intangible assets not
 allocated to segments may represent a significant portion of the
remainder. See ASC
 280-10-50-31 and 280-10-55-49 for guidance.
 March 11, 2026
Page 2

 Please contact SiSi Cheng at 202-551-5004 or Jennifer Thompson at
202-551-3737 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
</TEXT>
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