SEC Comment Letter 0000000000-23-011649 to Kraft Heinz Co (KHC) (CIK 0001637459) (KHC)
Kraft Heinz Co (KHC) (CIK 0001637459)
Date: Oct. 24, 2023 · CIK: 0001637459 · Accession: 0000000000-23-011649
AI Filing Summary & Sentiment
File numbers found in text: 001-37482
Letter
United States securities and exchange commission logo October 24, 2023 Andre Maciel Global Chief Financial Officer Kraft Heinz Company One PPG Place Pittsburgh, PA 15222 Re:Kraft Heinz Company Form 10-K for Fiscal Year Ended December 31, 2022 Form 10-Q for the Period Ended July 1, 2023 File No. 001-37482 Dear Andre Maciel: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-Q for the Period Ended July 1, 2023 Notes to Condensed Consolidated Financial Statements Note 7. Goodwill and Intangible Assets, page 11 1.We note your annual impairment test of June 26, 2022 and that no events occurred during the six months ended July 1, 2023 that indicated it was more likely than not that your goodwill or any brand was impaired. We further note that your market capitalization is less than the carrying value of your net assets. Given that goodwill and indefinite lived intangible assets are a significant percentage of your total assets, please tell us how you considered the declines in market capitalization and stock price in determining that an interim impairment test was not required in subsequent quarters. Please refer to ASC 350- 20-35-3C. 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.
FirstName LastNameAndre Maciel Comapany NameKraft Heinz Company October 24, 2023 Page 2 FirstName LastName Andre Maciel Kraft Heinz Company October 24, 2023 Page 2 Please contact Melissa Gilmore at 202-551-3777 or Kevin Woody at 202-551-3629 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
October 24, 2023
Andre Maciel
Global Chief Financial Officer
Kraft Heinz Company
One PPG Place
Pittsburgh, PA 15222
Re:Kraft Heinz Company
Form 10-K for Fiscal Year Ended December 31, 2022
Form 10-Q for the Period Ended July 1, 2023
File No. 001-37482
Dear Andre Maciel:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-Q for the Period Ended July 1, 2023
Notes to Condensed Consolidated Financial Statements
Note 7. Goodwill and Intangible Assets, page 11
1.We note your annual impairment test of June 26, 2022 and that no events occurred during
the six months ended July 1, 2023 that indicated it was more likely than not that your
goodwill or any brand was impaired. We further note that your market capitalization is
less than the carrying value of your net assets. Given that goodwill and indefinite lived
intangible assets are a significant percentage of your total assets, please tell us how you
considered the declines in market capitalization and stock price in determining that an
interim impairment test was not required in subsequent quarters. Please refer to ASC 350-
20-35-3C.
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.
FirstName LastNameAndre Maciel
Comapany NameKraft Heinz Company
October 24, 2023 Page 2
FirstName LastName
Andre Maciel
Kraft Heinz Company
October 24, 2023
Page 2
Please contact Melissa Gilmore at 202-551-3777 or Kevin Woody at 202-551-3629 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing