SEC Comment Letter 0000000000-23-011618 to LINDE PLC (LIN)
LINDE PLC
Date: Oct. 24, 2023 · CIK: 0001707925 · Accession: 0000000000-23-011618
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38730
Letter
United States securities and exchange commission logo October 24, 2023 Matthew White Chief Financial Officer LINDE PLC 10 Riverview Drive Danbury, Connecticut 06810 Re:LINDE PLC Form 10-K for the Year Ended December 31, 2022 File No. 001-38730 Dear Matthew White: 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-K for the Year Ended December 31, 2022 Critical Accounting Estimates, page 35 1.In light of the significant charges related to the deconsolidation of your Russian gas and engineering business entities as of June 30, 2022, please tell us what consideration was given to providing enhanced disclosures to identify the specific factors which led to your determination that you could no longer exercise control over these entities and to describe management's assumptions and estimates underlying (i) the probability weighted discounted cash flow model used to fair value your Russian subsidiaries and (ii) impairments of assets which are maintained by international entities in support of the Russian business.
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 LastNameMatthew White Comapany NameLINDE PLC October 24, 2023 Page 2 FirstName LastName Matthew White LINDE PLC October 24, 2023 Page 2 Please contact Nudrat Salik at 202-551-3692 or Jeanne Baker at 202-551-3691 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
October 24, 2023
Matthew White
Chief Financial Officer
LINDE PLC
10 Riverview Drive
Danbury, Connecticut 06810
Re:LINDE PLC
Form 10-K for the Year Ended December 31, 2022
File No. 001-38730
Dear Matthew White:
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-K for the Year Ended December 31, 2022
Critical Accounting Estimates, page 35
1.In light of the significant charges related to the deconsolidation of your Russian gas and
engineering business entities as of June 30, 2022, please tell us what consideration was
given to providing enhanced disclosures to identify the specific factors which led to your
determination that you could no longer exercise control over these entities and to describe
management's assumptions and estimates underlying (i) the probability weighted
discounted cash flow model used to fair value your Russian subsidiaries and (ii)
impairments of assets which are maintained by international entities in support of the
Russian business.
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 LastNameMatthew White
Comapany NameLINDE PLC
October 24, 2023 Page 2
FirstName LastName
Matthew White
LINDE PLC
October 24, 2023
Page 2
Please contact Nudrat Salik at 202-551-3692 or Jeanne Baker at 202-551-3691 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services