SEC Comment Letter for Varex Imaging Corp (VREX) (CIK 0001681622) (VREX) — Oct 27, 2016
Varex Imaging Corp (VREX) (CIK 0001681622)
Date: Oct. 27, 2016 · CIK: 0001681622 · Accession: 0000000000-16-098726
AI Filing Summary & Sentiment
File numbers found in text: 001-37860
Letter
Mail Stop 3030 October 27, 2016 Sunny S. Sanyal President and Chief Executive Officer Varex Imaging Corporation 1678 S. Pioneer Road Salt Lake City, Utah 84014
Re: Varex Imaging Corporation Amendment No.1 to Registration Statement on Form 10 -12B Filed October 11, 2016 File No. 001-37860
Dear Mr. Sanyal :
We have reviewed your filing an d 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 busine ss days by providing the requested information or advis e 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 and any amendment you may file in response to these comments , we may have additional comments.
Form 10
1. We note your responses to prior comments 1, 8 and 11. Please be advised that we may have further comments after you provide the information and exhibits in a future amendment in response to those comments.
Exhibit 99.1
Reasons for the Separation, page 14
2. We note your response to prior comment 4, howev er, your related revised disclosure does not appear to add any substantive disclosure as to why the Varian Medical board determined to complete the spin -off at this time if the conditions supporting the decision have existed previously. Please revise your disclosure as appropriate.
Sunny S. Sanyal Varex Imaging Corporation October 2 7, 2016 Page 2
You may contact Dennis Hult at (202) 551 -3618 or Kate Tillan, Assistant Chief Accountant, at (202) 551 -3604 if you have questions regarding comments on the financial statements and related matters. Please contact Tim Buchmille r at (202) 551 -3635 or Daniel Morris, Special Counsel, at (202) 551 -3314 with any other questions.
Sincerely,
/s/ Daniel Morris for
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Mail Stop 3030 October 27, 2016 Sunny S. Sanyal President and Chief Executive Officer Varex Imaging Corporation 1678 S. Pioneer Road Salt Lake City, Utah 84014 Re: Varex Imaging Corporation Amendment No.1 to Registration Statement on Form 10 -12B Filed October 11, 2016 File No. 001-37860 Dear Mr. Sanyal : We have reviewed your filing an d 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 busine ss days by providing the requested information or advis e 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 and any amendment you may file in response to these comments , we may have additional comments. Form 10 1. We note your responses to prior comments 1, 8 and 11. Please be advised that we may have further comments after you provide the information and exhibits in a future amendment in response to those comments. Exhibit 99.1 Reasons for the Separation, page 14 2. We note your response to prior comment 4, howev er, your related revised disclosure does not appear to add any substantive disclosure as to why the Varian Medical board determined to complete the spin -off at this time if the conditions supporting the decision have existed previously. Please revise your disclosure as appropriate. Sunny S. Sanyal Varex Imaging Corporation October 2 7, 2016 Page 2 You may contact Dennis Hult at (202) 551 -3618 or Kate Tillan, Assistant Chief Accountant, at (202) 551 -3604 if you have questions regarding comments on the financial statements and related matters. Please contact Tim Buchmille r at (202) 551 -3635 or Daniel Morris, Special Counsel, at (202) 551 -3314 with any other questions. Sincerely, /s/ Daniel Morris for Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: Ronald C. Chen, Esq. Wachtell, Lipton, Rosen & Katz