SecProbe.io

Filing text and metadata
Intelligence Terminal Search Topics Monthly Activity About

SEC Comment Letter 0000000000-25-002965 to TTM TECHNOLOGIES INC (TTMI)

TTM TECHNOLOGIES INC
Date: March 19, 2025 · CIK: 0001116942 · Accession: 0000000000-25-002965

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
March 19, 2025
Author
Division of
Form
UPLOAD
Company
TTM TECHNOLOGIES INC

Letter

Re: TTM Technologies, Inc. Form 10-K for the year ended December 30, 2024 File No. 0-32185 Dear Daniel Boehle:

March 19, 2025

Daniel Boehle Chief Financial Officer TTM Technologies, Inc. 200 East Sandpointe Suite 400 Santa Ana CA 92707

We have limited our review of your filing to the financial statements and related disclosures and have the following comments.

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.

Form 10-K for the year ended December 30, 2024 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 45

1. We note that you discuss your results of operations on a segment basis in terms of net sales and gross margin. Please explain to us what consideration you gave to discussing the change in segment operating income, your segment profitability measure disclosed in the notes to the financial statements, as part of your MD&A discussion. See guidance in Item 303(b) of Regulation S-K. Notes to the Consolidated Financial Statements Segment Information, page 85

2. Please refer to the reconciliation of net sales to segment operating income. Please tell us whether operating expenses represents a significant segment expense determined in accordance with ASC 280-10-50-26A or if it represents "other segment items" in accordance with ASC 280-10-50-26B. If the amount represents other segment items, March 19, 2025 Page 2

please tell us how you complied with the guidance in ASC 280-10-50-26B, including disclosure of a qualitative description of the composition of other segment items. Please advise. 3. We note your disclosure of "other profit or (loss)" in your reconciliation of total segment operating income to consolidated income before taxes. We also note from footnote (1) that this amount represents elimination of inter-segment sales, accelerated depreciation associated with plant closures, gain on sale of assets, unrealized gain/loss on commodity hedge, acquisition costs, non-cash goodwill impairment charge, restructuring, and purchase accounting related inventory markup. In light of the significance of this amount in each year presented, we believe that you should separately disclose all significant amounts in accordance with ASC 280-10-50-31. Please revise future filings accordingly. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Charles Eastman at 202-551-3794 or Claire Erlanger at 202-551-3301 with any questions.

Sincerely,
Division of
Corporation Finance
Office of
Manufacturing

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 19, 2025

Daniel Boehle
Chief Financial Officer
TTM Technologies, Inc.
200 East Sandpointe
Suite 400
Santa Ana CA 92707

 Re: TTM Technologies, Inc.
 Form 10-K for the year ended December 30, 2024
 File No. 0-32185
Dear Daniel Boehle:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 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.

Form 10-K for the year ended December 30, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 45

1. We note that you discuss your results of operations on a segment basis
in terms of net
 sales and gross margin. Please explain to us what consideration you gave
to
 discussing the change in segment operating income, your segment
profitability
 measure disclosed in the notes to the financial statements, as part of
your MD&A
 discussion. See guidance in Item 303(b) of Regulation S-K.
Notes to the Consolidated Financial Statements
Segment Information, page 85

2. Please refer to the reconciliation of net sales to segment operating
income. Please tell
 us whether operating expenses represents a significant segment expense
determined in
 accordance with ASC 280-10-50-26A or if it represents "other segment
items" in
 accordance with ASC 280-10-50-26B. If the amount represents other
segment items,
 March 19, 2025
Page 2

 please tell us how you complied with the guidance in ASC 280-10-50-26B,
including
 disclosure of a qualitative description of the composition of other
segment items.
 Please advise.
3. We note your disclosure of "other profit or (loss)" in your
reconciliation of total
 segment operating income to consolidated income before taxes. We also
note from
 footnote (1) that this amount represents elimination of inter-segment
sales, accelerated
 depreciation associated with plant closures, gain on sale of assets,
unrealized gain/loss
 on commodity hedge, acquisition costs, non-cash goodwill impairment
charge,
 restructuring, and purchase accounting related inventory markup. In
light of the
 significance of this amount in each year presented, we believe that you
should
 separately disclose all significant amounts in accordance with ASC
280-10-50-31.
 Please revise future filings accordingly.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Charles Eastman at 202-551-3794 or Claire Erlanger at
202-551-3301
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>