SEC Comment Letter for Varex Imaging Corp (VREX) (CIK 0001681622) (VREX) — Jan 17, 2017
Varex Imaging Corp (VREX) (CIK 0001681622)
Date: Jan. 17, 2017 · CIK: 0001681622 · Accession: 0000000000-17-001679
AI Filing Summary & Sentiment
File numbers found in text: 001-37860
Letter
Mail Stop 3030 January 17, 2017 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.4 to Registration Statement on Form 10 -12B Filed January 12, 2017 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.
Exhibit 99.1
Acquisition of PerkinElmer’s Medical Imaging Business, page 10
1. With respect to the acquisition of the PerkinElmer businesses and the related financing, please tell us your consideration of including audited financial statements of those businesses in the filing under Item 3 -05 of Regulation S -X alon g with the related pro forma financial information under Item 11 -01 of Regulation S -X.
Sunny S. Sanyal Varex Imaging Corporation January 17, 2017 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 Buchmiller at (202) 551 -3635 or Daniel Morris, Special Counsel, at (202) 551 -3314 with any other questions.
Sincerely,
/s/ Dan Morris for
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Mail Stop 3030 January 17, 2017 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.4 to Registration Statement on Form 10 -12B Filed January 12, 2017 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. Exhibit 99.1 Acquisition of PerkinElmer’s Medical Imaging Business, page 10 1. With respect to the acquisition of the PerkinElmer businesses and the related financing, please tell us your consideration of including audited financial statements of those businesses in the filing under Item 3 -05 of Regulation S -X alon g with the related pro forma financial information under Item 11 -01 of Regulation S -X. Sunny S. Sanyal Varex Imaging Corporation January 17, 2017 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 Buchmiller at (202) 551 -3635 or Daniel Morris, Special Counsel, at (202) 551 -3314 with any other questions. Sincerely, /s/ Dan Morris for Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: Ronald C. Chen, Esq. Wachtell, Lipton, Rosen & Katz