SEC Comment Letter 0000000000-24-013027 to Axalta Coating Systems Ltd. (AXTA) (CIK 0001616862) (AXTA)
Axalta Coating Systems Ltd. (AXTA) (CIK 0001616862)
Date: Nov. 22, 2024 · CIK: 0001616862 · Accession: 0000000000-24-013027
AI Filing Summary & Sentiment
File numbers found in text: 001-36733
Letter
November 22, 2024 Carl Anderson II Senior Vice President and Chief Financial Officer Axalta Coating Systems Ltd. 1050 Constitution Avenue Philadelphia, Pennsylvania 19112 Re:Axalta Coating Systems Ltd. Form 8-K filed August 1, 2024 File No. 001-36733 Dear Carl Anderson II: We have reviewed your November 6, 2024 response to our comment letter and have the following comment. 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 October 23, 2024 letter. Form 8-K Filed August 1, 2024 Exhibit 99.1, page 1 1.We note your response to comment two. The adjustment that excludes step-up depreciation and amortization associated with the acquisition of DuPont Performance Coatings results in the presentation of non-GAAP measures which reflect part, but not all, of an accounting concept. As such, the resulting non-GAAP measures substitute individually tailored recognition and measurement methods. Please revise your non- GAAP measures to remove this adjustment in future filings. Refer to 100.04 of the SEC Staff's Non-GAAP Compliance and Disclosure Interpretations.
November 22, 2024 Page 2 Please contact Nudrat Salik at 202-551-3692 or Jeanne Baker at 202-551-3691 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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November 22, 2024
Carl Anderson II
Senior Vice President and Chief Financial Officer
Axalta Coating Systems Ltd.
1050 Constitution Avenue
Philadelphia, Pennsylvania 19112
Re:Axalta Coating Systems Ltd.
Form 8-K filed August 1, 2024
File No. 001-36733
Dear Carl Anderson II:
We have reviewed your November 6, 2024 response to our comment letter and have
the following comment.
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 October
23, 2024 letter.
Form 8-K Filed August 1, 2024
Exhibit 99.1, page 1
1.We note your response to comment two. The adjustment that excludes step-up
depreciation and amortization associated with the acquisition of DuPont Performance
Coatings results in the presentation of non-GAAP measures which reflect part, but not
all, of an accounting concept. As such, the resulting non-GAAP measures substitute
individually tailored recognition and measurement methods. Please revise your non-
GAAP measures to remove this adjustment in future filings. Refer to 100.04 of the
SEC Staff's Non-GAAP Compliance and Disclosure Interpretations.
November 22, 2024
Page 2
Please contact Nudrat Salik at 202-551-3692 or Jeanne Baker at 202-551-3691 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services