SEC Comment Letter 0000000000-24-007329 to Innovex International, Inc. (INVX)
Innovex International, Inc.
Date: June 28, 2024 · CIK: 0001042893 · Accession: 0000000000-24-007329
AI Filing Summary & Sentiment
File numbers found in text: 001-13439
Letter
United States securities and exchange commission logo June 28, 2024 Jeffrey J. Bird Chief Executive Officer Dril-Quip, Inc. 2050 West Sam Houston Parkway S., Suite 1100 Houston, Texas 77042 Re:Dril-Quip, Inc. Form 10-K filed on February 27, 2024 Correspondence filed on June 24, 2024 File No. 001-13439 Dear Jeffrey J. Bird: We have reviewed your June 25, 2024 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 June 3, 2024 letter. Form 10-K for the year ending December 31, 2023 Note 9. Restructuring and other charges, page 71 1.We note your response to prior comment 4 and continue to believe that inventory markdowns should be classified in the income statement as a component of costs of goods sold. We refer you to ASC 420-10-S99-3. Please amend your Form 10-K for the year ending December 31, 2023.
FirstName LastNameJeffrey J. Bird Comapany NameDril-Quip, Inc. June 28, 2024 Page 2 FirstName LastName Jeffrey J. Bird Dril-Quip, Inc. June 28, 2024 Page 2 Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at 202-551-3488 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology
Show Raw Text
United States securities and exchange commission logo
June 28, 2024
Jeffrey J. Bird
Chief Executive Officer
Dril-Quip, Inc.
2050 West Sam Houston Parkway S., Suite 1100
Houston, Texas 77042
Re:Dril-Quip, Inc.
Form 10-K filed on February 27, 2024
Correspondence filed on June 24, 2024
File No. 001-13439
Dear Jeffrey J. Bird:
We have reviewed your June 25, 2024 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 June 3, 2024 letter.
Form 10-K for the year ending December 31, 2023
Note 9. Restructuring and other charges, page 71
1.We note your response to prior comment 4 and continue to believe that inventory
markdowns should be classified in the income statement as a component of costs of goods
sold. We refer you to ASC 420-10-S99-3. Please amend your Form 10-K for the year
ending December 31, 2023.
FirstName LastNameJeffrey J. Bird
Comapany NameDril-Quip, Inc.
June 28, 2024 Page 2
FirstName LastName
Jeffrey J. Bird
Dril-Quip, Inc.
June 28, 2024
Page 2
Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at 202-551-3488 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology