SEC Comment Letter for MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274) (MERC) — Dec 7, 2018
MERCER INTERNATIONAL INC. (MERC) (CIK 0001333274)
Date: Dec. 7, 2018 · CIK: 0001333274 · Accession: 0000000000-18-037501
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-51826
Letter
December 7, 2018 David K. Ure Chief Financial Officer Mercer International Inc. Suite 1120, 700 West Pender Street Vancouver, British Columbia, Canada, V6C 1G8 Re:Mercer International Inc. Form 10-K for Fiscal Year Ended December 31, 2017 Filed February 16, 2018 File No. 000-51826 Dear Mr. Ure: We have reviewed your filing 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. Form 10-K for Fiscal Year Ended December 31, 2017 Business Cash Production Costs, page 19 1.Revise your disclosure to clearly demonstrate how cash production costs per ADMT is calculated. Your revised disclosure should reconcile total cash production costs (numerator) to amounts disclosed in your consolidated statements of operations. Financial Statements Consolidated Statements of Operations, page 104 2.Explain to us how you have considered the requirement to disclose cost of sales on the face your statement of operations. See Rule 5-03(b)(2) of Regulation S-X.
FirstName LastNameDavid K. Ure Comapany NameMercer International Inc. December 7, 2018 Page 2 FirstName LastName David K. Ure Mercer International Inc. December 7, 2018 Page 2 Supplementary Financial Information (Unaudited), page 138 3.The amount you have reported as gross profit appears to be operating income. Explain to us how this presentation meets the requirements of Item 302(a)(1) of Regulation S-K. 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. You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 if you have questions regarding comments on the financial statements and related matters. Please contact Brad Skinner, Senior Assistant Chief Accountant, at 202-551-3489 with any other questions. Sincerely, Division of Corporation Finance Office of Natural Resources
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December 7, 2018
David K. Ure
Chief Financial Officer
Mercer International Inc.
Suite 1120, 700 West Pender Street
Vancouver, British Columbia, Canada, V6C 1G8
Re:Mercer International Inc.
Form 10-K for Fiscal Year Ended December 31, 2017
Filed February 16, 2018
File No. 000-51826
Dear Mr. Ure:
We have reviewed your filing 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.
Form 10-K for Fiscal Year Ended December 31, 2017
Business
Cash Production Costs, page 19
1.Revise your disclosure to clearly demonstrate how cash production costs per ADMT is
calculated. Your revised disclosure should reconcile total cash production costs
(numerator) to amounts disclosed in your consolidated statements of operations.
Financial Statements
Consolidated Statements of Operations, page 104
2.Explain to us how you have considered the requirement to disclose cost of sales on the
face your statement of operations. See Rule 5-03(b)(2) of Regulation S-X.
FirstName LastNameDavid K. Ure
Comapany NameMercer International Inc.
December 7, 2018 Page 2
FirstName LastName
David K. Ure
Mercer International Inc.
December 7, 2018
Page 2
Supplementary Financial Information (Unaudited), page 138
3.The amount you have reported as gross profit appears to be operating income. Explain to
us how this presentation meets the requirements of Item 302(a)(1) of Regulation S-K.
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.
You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 if you have
questions regarding comments on the financial statements and related matters. Please contact
Brad Skinner, Senior Assistant Chief Accountant, at 202-551-3489 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Natural Resources