UPLOAD Filing
ATI INC
Date: May 7, 2025 · CIK: 0001018963 · Accession: 0000000000-25-004843
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-12001
Referenced dates: April 22, 2025
Letter
Re: ATI Inc. Form 10-K for the Fiscal Year Ended December 29, 2024 Form 8-K furnished February 4, 2025 Response Letter dated April 22, 2025 File No. 001-12001 Dear Donald P. Newman:
May 7, 2025
Donald P. Newman Chief Financial Officer ATI Inc. 2021 McKinney Avenue Dallas, Texas 75201
We have reviewed your April 22, 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 March 14, 2025 letter.
Response Letter dated April 22, 2025 Management's Discussion and Analysis of Financial Condition and Results of Operations Results by Business Segment, page 24
1. We note from your response to our prior comment 1, that the reconciliation of Total Segment EBITDA to net income (by way of EBITDA and Adjusted EBITDA subtotals), includes an adjustment for corporate expenses. As these costs most likely represent normal operating costs of your business, they would not be an appropriate non-GAAP adjustment. Please revise future filings accordingly. See guidance in Question 100.01 of the C&DI on Non-GAAP Financial Measures. May 7, 2025 Page 2
Please contact Claire Erlanger at 202-551-3301 if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing
Show Raw Text
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> May 7, 2025 Donald P. Newman Chief Financial Officer ATI Inc. 2021 McKinney Avenue Dallas, Texas 75201 Re: ATI Inc. Form 10-K for the Fiscal Year Ended December 29, 2024 Form 8-K furnished February 4, 2025 Response Letter dated April 22, 2025 File No. 001-12001 Dear Donald P. Newman: We have reviewed your April 22, 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 March 14, 2025 letter. Response Letter dated April 22, 2025 Management's Discussion and Analysis of Financial Condition and Results of Operations Results by Business Segment, page 24 1. We note from your response to our prior comment 1, that the reconciliation of Total Segment EBITDA to net income (by way of EBITDA and Adjusted EBITDA subtotals), includes an adjustment for corporate expenses. As these costs most likely represent normal operating costs of your business, they would not be an appropriate non-GAAP adjustment. Please revise future filings accordingly. See guidance in Question 100.01 of the C&DI on Non-GAAP Financial Measures. May 7, 2025 Page 2 Please contact Claire Erlanger at 202-551-3301 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing </TEXT> </DOCUMENT>