SEC Comment Letter 0000000000-23-001514 to EnerSys (ENS) (CIK 0001289308) (ENS)
EnerSys (ENS) (CIK 0001289308)
Date: Feb. 14, 2023 · CIK: 0001289308 · Accession: 0000000000-23-001514
AI Filing Summary & Sentiment
File numbers found in text: 001-32253
Letter
United States securities and exchange commission logo February 14, 2023 Andrea Funk Chief Financial Officer EnerSys 2366 Bernville Rd. Reading, PA 19605 Re:EnerSys Form 10-K for the Fiscal Year Ended March 31, 2022 Filed May 25, 2022 File No. 001-32253 Dear Andrea Funk: We have reviewed your February 8, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our January 25, 2023 letter. Form 10-K for the Fiscal Year Ended March 31, 2022 Liquidity and Capital Resources Cash Flow and Financing Activities, page 42 1.We note your response to comment 1 indicates that your "use of the 'primary working capital' metric is more appropriately categorized as a key performance indicator (KPI)." It is our understanding that primary working capital is a non-GAAP measure and, therefore, it needs to comply with applicable rules that generally prohibit excluding charges or liabilities that required or will require cash settlement from non-GAAP liquidity measures. Accordingly, please revise future filings to ensure the measure complies with Item 10(e)(1)(ii)(A) of Regulation S-K.
FirstName LastNameAndrea Funk Comapany NameEnerSys February 14, 2023 Page 2 FirstName LastName Andrea Funk EnerSys February 14, 2023 Page 2 Please contact Andrew Blume, Staff Accountant, at (202) 551-3254 or Melissa Gilmore, Staff Accountant, at (202) 551-3777 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
February 14, 2023
Andrea Funk
Chief Financial Officer
EnerSys
2366 Bernville Rd.
Reading, PA 19605
Re:EnerSys
Form 10-K for the Fiscal Year Ended March 31, 2022
Filed May 25, 2022
File No. 001-32253
Dear Andrea Funk:
We have reviewed your February 8, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
January 25, 2023 letter.
Form 10-K for the Fiscal Year Ended March 31, 2022
Liquidity and Capital Resources
Cash Flow and Financing Activities, page 42
1.We note your response to comment 1 indicates that your "use of the 'primary working
capital' metric is more appropriately categorized as a key performance indicator (KPI)." It
is our understanding that primary working capital is a non-GAAP measure and, therefore,
it needs to comply with applicable rules that generally prohibit excluding charges or
liabilities that required or will require cash settlement from non-GAAP liquidity
measures. Accordingly, please revise future filings to ensure the measure complies with
Item 10(e)(1)(ii)(A) of Regulation S-K.
FirstName LastNameAndrea Funk
Comapany NameEnerSys
February 14, 2023 Page 2
FirstName LastName
Andrea Funk
EnerSys
February 14, 2023
Page 2
Please contact Andrew Blume, Staff Accountant, at (202) 551-3254 or Melissa Gilmore,
Staff Accountant, at (202) 551-3777 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing