SEC Comment Letter 0000000000-23-002200 to EAGLE MATERIALS INC (EXP) (CIK 0000918646) (EXP)
EAGLE MATERIALS INC (EXP) (CIK 0000918646)
Date: March 6, 2023 · CIK: 0000918646 · Accession: 0000000000-23-002200
AI Filing Summary & Sentiment
File numbers found in text: 001-12984
Letter
United States securities and exchange commission logo March 6, 2023 Craig Kesler Chief Financial Officer Eagle Materials Inc. 5960 Berkshire Lane, Suite 900 Dallas, Texas 75225 Re:Eagle Materials Inc. Form 10-K for the Fiscal Year Ended March 31, 2022 Filed May 20, 2022 File No. 001-12984 Dear Craig Kesler: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this comment 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 our comment apply to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended March 31, 2022 Management Discussion and Analysis of Financial Condition and Results of Operations Fiscal Year 2022 vs. Fiscal Year 2021 Results by Segment, page 43 1.We note that you present net revenue for certain of your segments, which excludes freight and delivery costs billed to customers. This appears to be a non-GAAP measure that would be considered individually tailored and have the effect of changing the recognition and measurement principles applied in accordance with GAAP. Please explain to us how you considered Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.
FirstName LastNameCraig Kesler Comapany NameEagle Materials Inc. March 6, 2023 Page 2 FirstName LastName Craig Kesler Eagle Materials Inc. March 6, 2023 Page 2 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. You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-557-3587 or Melissa Gilmore, Senior Staff Accountant, at 202-551-3777 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
March 6, 2023
Craig Kesler
Chief Financial Officer
Eagle Materials Inc.
5960 Berkshire Lane, Suite 900
Dallas, Texas 75225
Re:Eagle Materials Inc.
Form 10-K for the Fiscal Year Ended March 31, 2022
Filed May 20, 2022
File No. 001-12984
Dear Craig Kesler:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this comment 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 our
comment apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended March 31, 2022
Management Discussion and Analysis of Financial Condition and Results of Operations
Fiscal Year 2022 vs. Fiscal Year 2021 Results by Segment, page 43
1.We note that you present net revenue for certain of your segments, which excludes freight
and delivery costs billed to customers. This appears to be a non-GAAP measure that
would be considered individually tailored and have the effect of changing the recognition
and measurement principles applied in accordance with GAAP. Please explain to us how
you considered Question 100.04 of the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations.
FirstName LastNameCraig Kesler
Comapany NameEagle Materials Inc.
March 6, 2023 Page 2
FirstName LastName
Craig Kesler
Eagle Materials Inc.
March 6, 2023
Page 2
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.
You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-557-3587 or Melissa
Gilmore, Senior Staff Accountant, at 202-551-3777 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing