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UPLOAD Filing

IDEXX LABORATORIES INC /DE
Date: April 24, 2025 · CIK: 0000874716 · Accession: 0000000000-25-004362

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File numbers found in text: 000-19271

Date
April 24, 2025
Author
Division of
Form
UPLOAD
Company
IDEXX LABORATORIES INC /DE

Letter

Re: IDEXX Laboratories Inc. Form 10-K for the Fiscal Year Ended December 31, 2024 Filed February 21, 2025 File No. 000-19271 Dear Andrew Emerson:

April 24, 2025

Andrew Emerson Chief Financial Officer and Treasurer IDEXX Laboratories Inc. One IDEXX Drive Westbrook, Maine 04092

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

Form 10-K for the Fiscal Year Ended December 31, 2024 Notes to Consolidated Financial Statements Note 17. Segment Reporting, page F-40

1. We note that in prior periods, up to and including the nine months ended September 30, 2024, you presented Income from operations as your reported measure of segment profit or loss. It appears that you changed your reported measure of segment profit or loss upon the adoption of ASU 2023-07 and now disclose gross profit for each segment in addition to revenues. In your MD&A, however, you continue to present Income from operations for each segment, which includes reported amounts of sales and marketing, general and administrative and research and development expenses. Please clarify for us whether Income from operations for each segment is reported to the CODM and the extent to which this measure is used to evaluate segment performance and allocate resources. To the extent this measure is considered by the CODM when assessing performance and allocating resources, please explain how you determined the appropriate measure(s) to report under ASC 280-10-50- April 24, 2025 Page 2

28A. In this regard, at least one of the reported segment profit or loss measures shall be that which management believes is determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amounts in your consolidated financial statements. 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.

Please contact Frank Wyman at 202-551-3660 or Angela Connell at 202-551-3426 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
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<TEXT>
 April 24, 2025

Andrew Emerson
Chief Financial Officer and Treasurer
IDEXX Laboratories Inc.
One IDEXX Drive
Westbrook, Maine 04092

 Re: IDEXX Laboratories Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Filed February 21, 2025
 File No. 000-19271
Dear Andrew Emerson:

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

Form 10-K for the Fiscal Year Ended December 31, 2024
Notes to Consolidated Financial Statements
Note 17. Segment Reporting, page F-40

1. We note that in prior periods, up to and including the nine months ended
September
 30, 2024, you presented Income from operations as your reported measure
of segment
 profit or loss. It appears that you changed your reported measure of
segment profit or
 loss upon the adoption of ASU 2023-07 and now disclose gross profit for
each
 segment in addition to revenues. In your MD&A, however, you continue to
 present Income from operations for each segment, which includes reported
amounts of
 sales and marketing, general and administrative and research and
development
 expenses. Please clarify for us whether Income from operations for each
segment is
 reported to the CODM and the extent to which this measure is used to
evaluate
 segment performance and allocate resources. To the extent this measure
is considered
 by the CODM when assessing performance and allocating resources, please
explain
 how you determined the appropriate measure(s) to report under ASC
280-10-50-
 April 24, 2025
Page 2

 28A. In this regard, at least one of the reported segment profit or loss
measures shall
 be that which management believes is determined in accordance with the
 measurement principles most consistent with those used in measuring the
 corresponding amounts in your consolidated financial statements.
 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.

 Please contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
</DOCUMENT>