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UPLOAD Filing

LINDE PLC
Date: May 22, 2025 · CIK: 0001707925 · Accession: 0000000000-25-005474

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File numbers found in text: 001-38730

Date
May 22, 2025
Author
Division of
Form
UPLOAD
Company
LINDE PLC

Letter

Re: LINDE PLC Form 10-K for the Year Ended December 31, 2024 File No. 001-38730 Dear Matthew White:

May 22, 2025

Matthew White Chief Financial Officer LINDE PLC 10 Riverview Drive Danbury, Connecticut 06810

We have reviewed your filing 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, 2024 Non-GAAP Financial Measures, page 35

1. We note that your determination of multiple non-GAAP measures includes an adjustment for purchase accounting impacts - Linde AG. For the portion of this adjustment related to depreciation and amortization for the fair value step-up of fixed assets and intangible assets, please help us understand how you determined this adjustment is appropriate. Specifically, the adjustment results in these non-GAAP measures only reflecting part, but not all, of an accounting concept. Refer to Question 100.04 of the Division s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.

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. May 22, 2025 Page 2

Please contact Nudrat Salik at 202-551-3692 or Tracey Houser at 202-551-3736 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Industrial
Applications and
Services

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
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<TEXT>
 May 22, 2025

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, 2024
 File No. 001-38730
Dear Matthew White:

 We have reviewed your filing 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, 2024
Non-GAAP Financial Measures, page 35

1. We note that your determination of multiple non-GAAP measures includes
an
 adjustment for purchase accounting impacts - Linde AG. For the portion
of this
 adjustment related to depreciation and amortization for the fair value
step-up of fixed
 assets and intangible assets, please help us understand how you
determined this
 adjustment is appropriate. Specifically, the adjustment results in these
non-GAAP
 measures only reflecting part, but not all, of an accounting concept.
Refer to Question
 100.04 of the Division s Compliance & Disclosure Interpretations on
Non-GAAP
 Financial Measures.

 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.
 May 22, 2025
Page 2

 Please contact Nudrat Salik at 202-551-3692 or Tracey Houser at
202-551-3736 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
</TEXT>
</DOCUMENT>