SEC Company Response from ESCO TECHNOLOGIES (ESE) — Mar 18, 2026
ESCO TECHNOLOGIES INC
Date: March 18, 2026 · CIK: 0000866706 · Accession: 0001104659-26-030159
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-10596
Letter
Division of Corporation Finance Office of Manufacturing Securities and Exchange Commission Form 10-K for the year ended September 30, 2025 Filed December 1, 2025 File No. 001-10596
RE: ESCO Technologies Inc. (the Company)
Dear Ms. Cheng and Ms. Thompson:
This letter sets forth the response of ESCO Technologies Inc. (the "Company") to the comment letter of the Division of Corporation Finance of the Securities and Exchange Commission (the "Commission") dated March 11, 2026, with respect to the above referenced filing. We have duplicated the comment set forth in the comment letter and have provided our response below.
Form 10-K for the fiscal year ended September 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.
Company Response
In future filings, we will present the reconciliation from segment assets to consolidated asset totals in more detail by including the significant reconciling items, as outlined in Exhibit 1. Refer to the bolded highlighted rows in Exhibit 1 for revisions from our last response.
If you have any questions or if you require additional information, please do not hesitate to contact me by phone at 314-213-7245 or email at ctucker@escotechnologies.com
Sincerely,
Christopher L. Tucker
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CORRESP 1 filename1.htm March 18, 2026 SiSi Cheng and Jennifer Thompson Division of Corporation Finance Office of Manufacturing Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 RE: ESCO Technologies Inc. (the Company) Form 10-K for the year ended September 30, 2025 Filed December 1, 2025 File No. 001-10596 Dear Ms. Cheng and Ms. Thompson: This letter sets forth the response of ESCO Technologies Inc. (the "Company") to the comment letter of the Division of Corporation Finance of the Securities and Exchange Commission (the "Commission") dated March 11, 2026, with respect to the above referenced filing. We have duplicated the comment set forth in the comment letter and have provided our response below. Form 10-K for the fiscal year ended September 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. Company Response In future filings, we will present the reconciliation from segment assets to consolidated asset totals in more detail by including the significant reconciling items, as outlined in Exhibit 1. Refer to the bolded highlighted rows in Exhibit 1 for revisions from our last response. 1 If you have any questions or if you require additional information, please do not hesitate to contact me by phone at 314-213-7245 or email at ctucker@escotechnologies.com Sincerely, Christopher L. Tucker Senior Vice President & Chief Financial Officer ESCO Technologies Inc. 2 Exhibit 1 ESCO TECHNOLOGIES INC. AND SUBSIDIARIES Business Segment Information (in thousands) For Reference - FY 25 Business Segment Disclosures Only FY 25 A&D USG Test Segment Total Net Sales $ 478,192 379,995 237,201 1,095,388 Cost of sales 296,688 176,976 160,639 SG&A expense 53,050 99,520 38,987 Amortization of intangible assets 1,465 8,563 1,978 Other expense (income), net 1,850 195 1,486 Segment profit (loss) $ 125,139 94,741 34,111 253,991 Depreciation and Amortization $ 11,714 16,119 5,744 33,577 Segment Assets 409,789 289,505 206,944 906,238 Capital Expenditures $ 18,758 9,478 5,048 33,284 Reconciliation of segment profit to Earnings before Income Taxes Segment profit total from above $ 253,991 Less: Unallocated Corporate SG&A and Other expense (income), net (42,325 ) Unallocated amortization of intangible assets (41,311 ) Interest expense, net (17,502 ) Earnings before Income Taxes $ 152,853 Reconciliation of segment depreciation and amortization to consolidated totals Segment Depreciation and Amortization $ 33,577 Add: Corporate Depreciation and Amortization 41,444 Consolidated totals $ 75,021 Reconciliation of segment assets to consolidated totals Segment Assets total $ 906,238 Add: Goodwill not allocated to segments 761,931 Acquired intangible assets not allocated to segments 680,815 (1) Other unallocated amounts 61,404 Consolidated totals $ 2,410,388 (1) Consists of customer relationships, trade names and other intangible assets. See footnote XX for details. Reconciliation of segment capital expenditures to consolidated totals Segment Capital Expenditures $ 33,284 Add: Corporate Capital Expenditures 3,038 Consolidated totals $ 36,322