SecProbe.io

United States securities and exchange commission logo
December 16, 2022
Paul Oldham
Chief Financial Officer
Advanced Energy Industries, Inc.
1595 Wynkoop Street, Suite 800
Denver, Colorado 80202
Re:Advanced Energy Industries, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed March 16, 2022
File No. 000-26966
Dear Paul Oldham:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Continuing Operations , page 37
1.Please revise MD&A in future annual and quarterly filings to more fully address the
following:
•Disclose and discuss the specific reasons for the changes in demand by market during
each period presented;
•When you disclose and discuss multiple factors that impact your operations, quantify
the impact of each factor, for example, we note you identify multiple factors that
impact gross profit;
•You disclose here, and in quarterly filings, that the decrease in gross profit as
a percent of revenue is largely related to higher material and freight costs, as well as
productivity inefficiencies resulting from supply constraints. Discuss whether and
how supply chain disruptions materially affect your outlook or business

 FirstName LastNamePaul Oldham
 Comapany NameAdvanced Energy Industries, Inc.
 December 16, 2022 Page 2
 FirstName LastName
Paul Oldham
Advanced Energy Industries, Inc.
December 16, 2022
Page 2
goals. Quantify and disclose, to the extent possible, how sales, profits, and/or
liquidity have been impacted and discuss known trends or uncertainties resulting
from any mitigation efforts being undertaken, including whether mitigation efforts
introduce new material risks related to product quality, reliability, or regulatory
approval; and
•You disclose here, and in quarterly filings, that you are experiencing price increases
in select components and, to the extent permitted, you pass increased costs on to
customers. Quantify and disclose the impact of the inflationary pressures you
experience and update your disclosures to indicate the extent to which you are able to
pass increased costs on to customers to mitigate the inflationary pressures.
Consolidated Financial Statements
Note 3. Revenue, page 64
2.We note you disclose revenue by geographical region. Please tell us your consideration
for presenting revenue for each material individual foreign country as required by ASC
280-10-50-41. We also note your risk factor disclosure related to your operations in
China. To enable investors to more fully understand and evaluate this risk, please revise
future filings to quantify your operations in China, including sales and purchases related
to China.
            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 Dale Welcome at 202-551-3865 or Anne McConnell at 202-551-3709
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing