SEC Comment Letter 0000000000-24-010922 to ADTRAN Holdings, Inc. (ADTN) (CIK 0000926282) (ADTN)
ADTRAN Holdings, Inc. (ADTN) (CIK 0000926282)
Date: Sept. 26, 2024 · CIK: 0000926282 · Accession: 0000000000-24-010922
AI Filing Summary & Sentiment
File numbers found in text: 001-41446
Letter
September 25, 2024 Ulrich Dopfer Chief Financial Officer ADTRAN Holdings, Inc. 901 Explorer Boulevard Huntsville, AL 35806 Re:ADTRAN Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 File No. 001-41446 Dear Ulrich Dopfer: We have reviewed your filing 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 Fiscal Year Ended December 31, 2023 Item 11. Executive Compensation, page 137 1.From the disclosure incorporated by reference from page 45 of the Definitive Proxy Statement filed on March 27, 2024, it appears that you have not provided your disclosure about your recovery analysis in an Interactive Data File in accordance with Rule 405 of Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a recovery analysis, please also include the interactive data.
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.
September 25, 2024 Page 2 Please contact Tyler Howes at 202-551-3370 or James Lopez at 202-551-3536 with any questions. Sincerely, Division of Corporation Finance Office of Finance
Show Raw Text
September 25, 2024
Ulrich Dopfer
Chief Financial Officer
ADTRAN Holdings, Inc.
901 Explorer Boulevard
Huntsville, AL 35806
Re:ADTRAN Holdings, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-41446
Dear Ulrich Dopfer:
We have reviewed your filing 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 Fiscal Year Ended December 31, 2023
Item 11. Executive Compensation, page 137
1.From the disclosure incorporated by reference from page 45 of the Definitive Proxy
Statement filed on March 27, 2024, it appears that you have not provided your disclosure
about your recovery analysis in an Interactive Data File in accordance with Rule 405 of
Regulation S-T and the EDGAR Filer Manual. In future filings where you conduct a
recovery analysis, please also include the interactive data.
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.
September 25, 2024
Page 2
Please contact Tyler Howes at 202-551-3370 or James Lopez at 202-551-3536 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance