SEC Comment Letter for CIRCOR INTERNATIONAL INC (CIK 0001091883) — Nov 7, 2022
CIRCOR INTERNATIONAL INC (CIK 0001091883)
Date: Nov. 7, 2022 · CIK: 0001091883 · Accession: 0000000000-22-012102
AI Filing Summary & Sentiment
File numbers found in text: 001-14962
Letter
United States securities and exchange commission logo November 7, 2022 Arjun Sharma Chief Financial Officer CIRCOR International, Inc. 30 Corporate Drive, Suite 200 Burlington, MA 01803-4238 Re:CIRCOR International, Inc. Form 10-K for the Year Ended December 31, 2021 Form 10-Q for the Fiscal Quarter Ended July 3, 2022 Form 8-K furnished September 30, 2022 File No. 001-14962 Dear Arjun Sharma: We have reviewed your October 27, 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 September 14, 2022 letter. Form 10-Q for the Fiscal Quarter Ended July 3, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Segment Results, page 30 1.Your response to prior comment 1 indicates that you will no longer present orders as a non-GAAP measure and have determined it is instead a metric. Please revise to provide a clear definition of the metric and how it is calculated, why it is useful to investors, how management uses the metric and whether there are estimates or assumptions underlying the metric or its calculation for which disclosure is needed. Refer to SEC Release No. 33- 10751.
FirstName LastNameArjun Sharma Comapany NameCIRCOR International, Inc. November 7, 2022 Page 2 FirstName LastName Arjun Sharma CIRCOR International, Inc. November 7, 2022 Page 2 Form 8-K furnished September 30, 2022 Exhibit 99.2, page 22 2.Your response to prior comment 6 indicated that you would retitle free cash flow to adjusted free cash flow. Although you have done so in Exhibit 99.1, you did not revise the description on page 22 of Exhibit 99.2. Please revise future filings accordingly. You may contact Heather Clark at 202-551-3624 or Andrew Blume at 202-551-3254 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
November 7, 2022
Arjun Sharma
Chief Financial Officer
CIRCOR International, Inc.
30 Corporate Drive, Suite 200
Burlington, MA 01803-4238
Re:CIRCOR International, Inc.
Form 10-K for the Year Ended December 31, 2021
Form 10-Q for the Fiscal Quarter Ended July 3, 2022
Form 8-K furnished September 30, 2022
File No. 001-14962
Dear Arjun Sharma:
We have reviewed your October 27, 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
September 14, 2022 letter.
Form 10-Q for the Fiscal Quarter Ended July 3, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Segment Results, page 30
1.Your response to prior comment 1 indicates that you will no longer present orders as a
non-GAAP measure and have determined it is instead a metric. Please revise to provide a
clear definition of the metric and how it is calculated, why it is useful to investors, how
management uses the metric and whether there are estimates or assumptions underlying
the metric or its calculation for which disclosure is needed. Refer to SEC Release No. 33-
10751.
FirstName LastNameArjun Sharma
Comapany NameCIRCOR International, Inc.
November 7, 2022 Page 2
FirstName LastName
Arjun Sharma
CIRCOR International, Inc.
November 7, 2022
Page 2
Form 8-K furnished September 30, 2022
Exhibit 99.2, page 22
2.Your response to prior comment 6 indicated that you would retitle free cash flow to
adjusted free cash flow. Although you have done so in Exhibit 99.1, you did not revise
the description on page 22 of Exhibit 99.2. Please revise future filings accordingly.
You may contact Heather Clark at 202-551-3624 or Andrew Blume at 202-551-3254 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing