SEC Comment Letter 0000000000-22-013424 to ELBIT SYSTEMS LTD (ESLT) (CIK 0001027664) (ESLT)
ELBIT SYSTEMS LTD (ESLT) (CIK 0001027664)
Date: Dec. 13, 2022 · CIK: 0001027664 · Accession: 0000000000-22-013424
AI Filing Summary & Sentiment
File numbers found in text: 000-28998
Referenced dates: December 12, 2022
Letter
United States securities and exchange commission logo December 13, 2022 Kobi Kagan Chief Financial Officer ELBIT SYSTEMS LTD Advanced Technology Center PO Box 539 Haifa 3100401, Israel Re:ELBIT SYSTEMS LTD Form 20-F for the Year Ended December 31, 2021 Response Letter dated December 12, 2022 File No. 000-28998 Dear Kobi Kagan: We have reviewed your December 12, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our November 7, 2022 letter. Response Letter dated December 12, 2022 Note 23. Major Customers and Geographic Information, page F-73 1.We note from your response to our prior comment 5 that the financial information produced by the BU includes a managerial profit and loss, however this information is not used by the CODM for resource allocation. Please explain to us how this information is used by the CODM. Also, please identify for us the financial information that is used by the CODM to allocate resources throughout the Company. Additionally, we note from your website that there is a General Manager for each of the BUs. Please explain to us the roles and responsibilities of these General Managers and tell us how they are compensated. Lastly, please provide us detail on your budgeting process. As part of your response, explain how budgets are prepared, who approves the budget at each step of the
FirstName LastNameKobi Kagan Comapany NameELBIT SYSTEMS LTD December 13, 2022 Page 2 FirstName LastName Kobi Kagan ELBIT SYSTEMS LTD December 13, 2022 Page 2 process, the level of detail discussed at each step, and the level at which the CODM makes changes to the budget. You may contact Claire Erlanger at (202) 551-3301 or Kevin Woody at (202) 551-3629 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
December 13, 2022
Kobi Kagan
Chief Financial Officer
ELBIT SYSTEMS LTD
Advanced Technology Center
PO Box 539
Haifa 3100401, Israel
Re:ELBIT SYSTEMS LTD
Form 20-F for the Year Ended December 31, 2021
Response Letter dated December 12, 2022
File No. 000-28998
Dear Kobi Kagan:
We have reviewed your December 12, 2022 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
November 7, 2022 letter.
Response Letter dated December 12, 2022
Note 23. Major Customers and Geographic Information, page F-73
1.We note from your response to our prior comment 5 that the financial information
produced by the BU includes a managerial profit and loss, however this information is not
used by the CODM for resource allocation. Please explain to us how this information is
used by the CODM. Also, please identify for us the financial information that is used by
the CODM to allocate resources throughout the Company. Additionally, we note from
your website that there is a General Manager for each of the BUs. Please explain to us the
roles and responsibilities of these General Managers and tell us how they are
compensated. Lastly, please provide us detail on your budgeting process. As part of your
response, explain how budgets are prepared, who approves the budget at each step of the
FirstName LastNameKobi Kagan
Comapany NameELBIT SYSTEMS LTD
December 13, 2022 Page 2
FirstName LastName
Kobi Kagan
ELBIT SYSTEMS LTD
December 13, 2022
Page 2
process, the level of detail discussed at each step, and the level at which the CODM makes
changes to the budget.
You may contact Claire Erlanger at (202) 551-3301 or Kevin Woody at (202) 551-3629 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing