SEC Comment Letter for ASHLAND INC. (ASH) (CIK 0001674862) (ASH) — Mar 25, 2020
ASHLAND INC. (ASH) (CIK 0001674862)
Date: March 25, 2020 · CIK: 0001674862 · Accession: 0000000000-20-002590
AI Filing Summary & Sentiment
File numbers found in text: 333-211719
Letter
March 20, 2020 J. Kevin Willis Senior Vice President and Chief Financial Officer Ashland Global Holdings Inc. 50 E. RiverCenter Boulevard Covington , Kentucky 41011 Re:Ashland Global Holdings Inc. Form 10-K for Fiscal Year Ended September 30, 2019 Filed November 25, 2019 File No. 333-211719 Dear Mr. Willis: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for Fiscal Year Ended September 30, 2019 MD&A Results of Operations - Consolidated Review, page M-3 1.We note your discussion and reconciliation of non-GAAP measures precedes your caption review of results on a consolidated and segment basis under GAAP. Please revise to provide prominence to your discussion and analysis of GAAP results. Refer to non- GAAP C&DI 102.10.
FirstName LastNameJ. Kevin Willis Comapany NameAshland Global Holdings Inc. March 20, 2020 Page 2 FirstName LastName J. Kevin Willis Ashland Global Holdings Inc. March 20, 2020 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 Aamira Chaudhry at 202-551-3389 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
Show Raw Text
March 20, 2020
J. Kevin Willis
Senior Vice President and Chief Financial Officer
Ashland Global Holdings Inc.
50 E. RiverCenter Boulevard
Covington , Kentucky 41011
Re:Ashland Global Holdings Inc.
Form 10-K for Fiscal Year Ended September 30, 2019
Filed November 25, 2019
File No. 333-211719
Dear Mr. Willis:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended September 30, 2019
MD&A
Results of Operations - Consolidated Review, page M-3
1.We note your discussion and reconciliation of non-GAAP measures precedes your caption
review of results on a consolidated and segment basis under GAAP. Please revise to
provide prominence to your discussion and analysis of GAAP results. Refer to non-
GAAP C&DI 102.10.
FirstName LastNameJ. Kevin Willis
Comapany NameAshland Global Holdings Inc.
March 20, 2020 Page 2
FirstName LastName
J. Kevin Willis
Ashland Global Holdings Inc.
March 20, 2020
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 Aamira Chaudhry at 202-551-3389 or Lyn Shenk at 202-551-3380 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services