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SEC Comment Letter for Enovis CORP (ENOV) (CIK 0001420800) (ENOV) — Dec 22, 2025

Enovis CORP (ENOV) (CIK 0001420800)
Date: Dec. 22, 2025 · CIK: 0001420800 · Accession: 0000000000-25-011735

Financial Reporting Regulatory Compliance

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File numbers found in text: 001-34045

Date
December 22, 2025
Author
Services
Form
UPLOAD
Company
Enovis CORP (ENOV) (CIK 0001420800)

Letter

Re: Enovis Corporation Form 10-K for the Fiscal Year Ended December 31, 2024 Form 10-Q for the Fiscal Quarter Ended October 3, 2025 File No. 001-34045 Dear Phillip B. Berry:

December 22, 2025

Phillip B. Berry Chief Financial Officer Enovis Corporation 2711 Centerville Road, Suite 400 Wilmington, Delaware 19808

We have reviewed your August 5, 2025 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our July 22, 2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024 Consolidated Financial Statements Note 19. Segment Information, page 106

1. You disclose the chief operating decision maker (CODM) evaluates the operating results of each of your reportable segments based upon Net sales and Adjusted EBITDA. We also note that your Management s Discussion and Analysis includes disclosure of gross profit and operating loss (GAAP) by reportable segment. Please tell us whether gross profit and operating loss (GAAP) by reportable segment are reported to the CODM and the extent to which each measure is used to evaluate segment performance and allocate resources. If either of these measures are considered by the CODM when assessing performance and allocating resources, please explain how you determined the appropriate measure to report under ASC 280- 10-50-28A. Finally, revise to disclose how the CODM uses the reported measure of December 22, 2025 Page 2

segment profit or loss in assessing segment performance and deciding how to allocate resources. Refer to ASC 280-10-50-29(f) and the example in ASC 280-10-55-47(bb). Form 10-Q for the Fiscal Quarter Ended October 3, 2025 Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Measures, page 31

2. We reference your response to prior comment 1. It appears that the non-GAAP adjustment for the purchase of royalty interest is related to a normal recurring operating expense for which a non-GAAP adjustment would be inconsistent with Question 100.01 of the Compliance & Disclosure Interpretations (C&DI) for Non- GAAP Financial Measures. In that regard, we note that the underlying intellectual property developed in connection with the related agreements continues to be incorporated into the company's products. Therefore, it appears that those costs relate to the generation of revenue and would be considered normal operating expenses. Please revise your presentation to remove the adjustment for purchase of royalty interest from your Adjusted EBITDA measures in future filings as well as the presentation of Adjusted Net Income included in the press release on Form 8- K. Alternatively, tell us why you continue to believe that the adjustment is consistent with the C&DI. 3. Reference the non-GAAP adjustment related to Inventory step-up. Please tell us why you believe an adjustment for inventory step-up charges in connection with acquired businesses does not change the recognition and measurement principles required to be applied in accordance with GAAP. Refer to Question 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Alternatively, please revise your presentation to remove this non-GAAP adjustment to Adjusted net income and Adjusted EBITDA measures in future filings, including the presentation in the press release on Form 8-K. 4. We note that you continue to include material non-GAAP adjustments for strategic transaction costs. Please tell us why you continue to adjust your non-GAAP measures for these costs and explain why they are not normal, recurring cash operating costs. With your response, please include information abut the expenses/(benefits) incurred through September 30, 2025. In addition, describe in more detail the nature of the payroll costs and retention expenses for which non-GAAP adjustments were made in 2024 and 2025. Please reference Question 100.01 of the C&DI for Non-GAAP Financial Measures. December 22, 2025 Page 3

Please contact Kristin Lochhead at 202-551-3664 or Li Xiao at 202-551-4391 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Industrial
Applications and
Services

Show Raw Text
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<TEXT>
 December 22, 2025

Phillip B. Berry
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, 2024
 Form 10-Q for the Fiscal Quarter Ended October 3, 2025
 File No. 001-34045
Dear Phillip B. Berry:

 We have reviewed your August 5, 2025 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in
our July 22,
2025 letter.

Form 10-K for the Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Note 19. Segment Information, page 106

1. You disclose the chief operating decision maker (CODM) evaluates the
operating
 results of each of your reportable segments based upon Net sales and
Adjusted
 EBITDA. We also note that your Management s Discussion and Analysis
includes
 disclosure of gross profit and operating loss (GAAP) by reportable
segment. Please
 tell us whether gross profit and operating loss (GAAP) by reportable
segment are
 reported to the CODM and the extent to which each measure is used to
evaluate
 segment performance and allocate resources. If either of these measures
are
 considered by the CODM when assessing performance and allocating
resources,
 please explain how you determined the appropriate measure to report
under ASC 280-
 10-50-28A. Finally, revise to disclose how the CODM uses the reported
measure of
 December 22, 2025
Page 2

 segment profit or loss in assessing segment performance and deciding how
to allocate
 resources. Refer to ASC 280-10-50-29(f) and the example in ASC
280-10-55-47(bb).
Form 10-Q for the Fiscal Quarter Ended October 3, 2025
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Non-GAAP Measures, page 31

2. We reference your response to prior comment 1. It appears that the
non-GAAP
 adjustment for the purchase of royalty interest is related to a normal
recurring
 operating expense for which a non-GAAP adjustment would be inconsistent
with
 Question 100.01 of the Compliance & Disclosure Interpretations (C&DI)
for Non-
 GAAP Financial Measures. In that regard, we note that the underlying
intellectual
 property developed in connection with the related agreements continues
to be
 incorporated into the company's products. Therefore, it appears that
those costs relate
 to the generation of revenue and would be considered normal operating
expenses.
 Please revise your presentation to remove the adjustment for purchase of
royalty
 interest from your Adjusted EBITDA measures in future filings as well as
the
 presentation of Adjusted Net Income included in the press release on
Form 8-
 K. Alternatively, tell us why you continue to believe that the
adjustment is consistent
 with the C&DI.
3. Reference the non-GAAP adjustment related to Inventory step-up. Please
tell us why
 you believe an adjustment for inventory step-up charges in connection
with acquired
 businesses does not change the recognition and measurement principles
required to be
 applied in accordance with GAAP. Refer to Question 100.04 of the
Compliance and
 Disclosure Interpretations on Non-GAAP Financial Measures.
Alternatively, please
 revise your presentation to remove this non-GAAP adjustment to Adjusted
net
 income and Adjusted EBITDA measures in future filings, including the
presentation
 in the press release on Form 8-K.
4. We note that you continue to include material non-GAAP adjustments for
strategic
 transaction costs. Please tell us why you continue to adjust your
non-GAAP measures
 for these costs and explain why they are not normal, recurring cash
operating costs.
 With your response, please include information abut the
expenses/(benefits) incurred
 through September 30, 2025. In addition, describe in more detail the
nature of
 the payroll costs and retention expenses for which non-GAAP adjustments
were made
 in 2024 and 2025. Please reference Question 100.01 of the C&DI for
Non-GAAP
 Financial Measures.
 December 22, 2025
Page 3

 Please contact Kristin Lochhead at 202-551-3664 or Li Xiao at
202-551-4391 if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
</TEXT>
</DOCUMENT>