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SEC Comment Letter 0000000000-22-012649 to Enovis CORP (ENOV) (CIK 0001420800) (ENOV)

Enovis CORP (ENOV) (CIK 0001420800)
Date: Nov. 22, 2022 · CIK: 0001420800 · Accession: 0000000000-22-012649

Financial Reporting Regulatory Compliance Internal Controls

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File numbers found in text: 001-34045

Date
November 22, 2022
Author
Kristin Lochhead
Form
UPLOAD
Company
Enovis CORP (ENOV) (CIK 0001420800)

Letter

United States securities and exchange commission logo November 22, 2022 Christopher Hix Chief Financial Officer Enovis Corporation 2711 Centerville Road, Suite 400 Wilmington, Delaware 19808 Re:Enovis Corporation Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 22, 2022 Form 10-Q for the Quarterly Period Ended September 30, 2022 Filed November 2, 2022 File No. 001-34045 Dear Christopher Hix: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-Q for the Quarterly Period Ended September 30, 2022 Condensed Consolidated Financial Statements for the Nine Months Ended September 30, 2022 Note 14. Segment Information, page 23 1.We note that you reconcile segment Adjusted EBITDA to operating loss. Please explain to us how this reconciliation is consistent with the guidance in ASC 280-10-50-30(b) that requires a reconciliation of the reportable segments' measures of profit or loss to consolidated income before income taxes and discontinued operations. In addition, tell us how you considered Question 103.02 of the Compliance & Disclosure Interpretations for Non-GAAP Financial Measures dated April 4, 2018 in your reconciliation to Adjusted EBITDA (non-GAAP) in MD&A on pages 31 and 32.

FirstName LastNameChristopher Hix Comapany NameEnovis Corporation November 22, 2022 Page 2 FirstName LastName Christopher Hix Enovis Corporation November 22, 2022 Page 2 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. You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio, Accounting Branch Chief, at (202) 551-3676 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services

Show Raw Text
United States securities and exchange commission logo
November 22, 2022
Christopher Hix
Chief Financial Officer
Enovis Corporation
2711 Centerville Road, Suite 400
Wilmington, Delaware 19808
Re:Enovis Corporation
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 22, 2022
Form 10-Q for the Quarterly Period Ended September 30, 2022
Filed November 2, 2022
File No. 001-34045
Dear Christopher Hix:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-Q for the Quarterly Period Ended September 30, 2022
Condensed Consolidated Financial Statements for the Nine Months Ended September 30, 2022
Note 14. Segment Information, page 23
1.We note that you reconcile segment Adjusted EBITDA to operating loss. Please explain to
us how this reconciliation is consistent with the guidance in ASC 280-10-50-30(b) that
requires a reconciliation of the reportable segments' measures of profit or loss to
consolidated income before income taxes and discontinued operations.  In addition, tell us
how you considered Question 103.02 of the Compliance & Disclosure Interpretations for
Non-GAAP Financial Measures dated April 4, 2018 in your reconciliation to Adjusted
EBITDA (non-GAAP) in MD&A on pages 31 and 32.

 FirstName LastNameChristopher Hix
 Comapany NameEnovis Corporation
 November 22, 2022 Page 2
 FirstName LastName
Christopher Hix
Enovis Corporation
November 22, 2022
Page 2
            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.
            You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio, Accounting
Branch Chief, at (202) 551-3676 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services