SEC Comment Letter for GLOBAL INDUSTRIAL Co (GIC) (CIK 0000945114) (GIC) — Jun 30, 2020
GLOBAL INDUSTRIAL Co (GIC) (CIK 0000945114)
Date: June 30, 2020 · CIK: 0000945114 · Accession: 0000000000-20-005872
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo June 30, 2020 Barry Litwin President and Chief Executive Officer Systemax Inc. 11 Harbor Park Drive Port Washington, New York 11050 Re:Systemax Inc. Form 10-K for the Fiscal Year Ended December 31, 2019 Response Dated June 19, 2020 File No. 1-13792 Dear Mr. Litwin: We have reviewed your June 19, 2020 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. 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 applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our May 13, 2020 letter. Form 10-K for the Fiscal Year Ended December 31, 2019 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Highlights from 2019, page 22 1.You state in your response to comment 1 that you disclose Average Day Sales (ADS) on a GAAP basis. We note you disclose the percentage increase in ADS on a constant currency basis on page 22 and ADS and the percentage increase in ADS on a constant currency basis on page 24. However, we are unable to locate your disclosure of ADS and the percentage increase in ADS on a GAAP basis. Please tell us where you disclose ADS and the percentage increase in ADS on a GAAP basis or revise your disclosure in future filings accordingly. Please refer to the Staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures, Question 104.06 found at https://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm.
FirstName LastNameBarry Litwin Comapany NameSystemax Inc. June 30, 2020 Page 2 FirstName LastName Barry Litwin Systemax Inc. June 30, 2020 Page 2
You may contact Scott Stringer at 202-551-3272 or me at 202-551-3344 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
June 30, 2020
Barry Litwin
President and Chief Executive Officer
Systemax Inc.
11 Harbor Park Drive
Port Washington, New York 11050
Re:Systemax Inc.
Form 10-K for the Fiscal Year Ended December 31, 2019
Response Dated June 19, 2020
File No. 1-13792
Dear Mr. Litwin:
We have reviewed your June 19, 2020 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
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 applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
May 13, 2020 letter.
Form 10-K for the Fiscal Year Ended December 31, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Highlights from 2019, page 22
1.You state in your response to comment 1 that you disclose Average Day Sales (ADS) on a
GAAP basis. We note you disclose the percentage increase in ADS on a constant
currency basis on page 22 and ADS and the percentage increase in ADS on a constant
currency basis on page 24. However, we are unable to locate your disclosure of ADS and
the percentage increase in ADS on a GAAP basis. Please tell us where you disclose ADS
and the percentage increase in ADS on a GAAP basis or revise your disclosure in future
filings accordingly. Please refer to the Staff's Compliance and Disclosure Interpretations
on Non-GAAP Financial Measures, Question 104.06 found
at https://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm.
FirstName LastNameBarry Litwin
Comapany NameSystemax Inc.
June 30, 2020 Page 2
FirstName LastName
Barry Litwin
Systemax Inc.
June 30, 2020
Page 2
You may contact Scott Stringer at 202-551-3272 or me at 202-551-3344 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services