SEC Comment Letter 0000000000-23-005703 to ICF International, Inc. (ICFI) (CIK 0001362004) (ICFI)
ICF International, Inc. (ICFI) (CIK 0001362004)
Date: May 30, 2023 · CIK: 0001362004 · Accession: 0000000000-23-005703
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United States securities and exchange commission logo
May 30, 2023
John Wasson
Chief Executive Officer
ICF International, Inc.
1902 Reston Metro Plaza
Reston, VA 20190
Re:ICF International, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Response dated May 12, 2023
File No. 1-33045
Dear John Wasson:
We have reviewed your May 12, 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
May 1, 2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures
Service Revenues, page 45
1.We note your response to comment 2. Your deduction of subcontractor and other direct
costs as if you were acting as an agent in these transactions, appears to result in an
individually tailored recognition method. Please revise your presentation to omit this
adjustment or tell us why you believe it is appropriate. Refer to Question 100.04 of
Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameJohn Wasson
Comapany NameICF International, Inc.
May 30, 2023 Page 2
FirstName LastName
John Wasson
ICF International, Inc.
May 30, 2023
Page 2
You may contact Tony Watson at (202) 551-3318 or Joel Parker at (202) 551-3651 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services