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UPLOAD Filing

IDEXX LABORATORIES INC /DE
Date: May 21, 2025 · CIK: 0000874716 · Accession: 0000000000-25-005409

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File numbers found in text: 000-19271

Date
May 21, 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:

May 21, 2025

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

We have reviewed your April 30, 2025 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 April 24, 2025 letter.

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 your response to our prior comment. You disclose on page F-40 that foreign currency transaction gains and losses are reported within your Other operating segment." Please explain in detail how, when you identified your operating segments, you determined foreign currency transaction gains or losses would be included in your Other operating segment and not in your operating segments that are reportable. As part of your response, please address the following: You indicate in the proposed disclosure in your response that foreign currency transaction gains and losses are centrally managed by your corporate treasury function. Describe the Other operating segment in further detail and how foreign currency transactions gains and losses are managed. May 21, 2025 Page 2

Describe the balance(s) that foreign currency transaction gains and losses are associated with. In this regard, we note your disclosure on page F-40 that assets are not allocated to segments for internal reporting purposes." Tell us how the Impact from foreign currency contained in the proposed disclosure in your response was calculated for each reportable segment, and whether the CODM is provided with this information.

Please contact Frank Wyman at 202-551-3660 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 May 21, 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 reviewed your April 30, 2025 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 April 24,
2025 letter.

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 your response to our prior comment. You disclose on page F-40
that foreign
 currency transaction gains and losses are reported within your Other
operating
 segment." Please explain in detail how, when you identified your
operating segments,
 you determined foreign currency transaction gains or losses would be
included in your
 Other operating segment and not in your operating segments that
are reportable. As
 part of your response, please address the following:
 You indicate in the proposed disclosure in your response that
foreign currency
 transaction gains and losses are centrally managed by your corporate
treasury
 function. Describe the Other operating segment in further
detail and how
 foreign currency transactions gains and losses are managed.
 May 21, 2025
Page 2

 Describe the balance(s) that foreign currency transaction gains
and losses are
 associated with. In this regard, we note your disclosure on page
F-40 that assets
 are not allocated to segments for internal reporting purposes."
 Tell us how the Impact from foreign currency contained in
the proposed
 disclosure in your response was calculated for each reportable
segment, and
 whether the CODM is provided with this information.

 Please contact Frank Wyman at 202-551-3660 or Angela Connell at
202-551-3426 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

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