SEC Comment Letter 0000000000-24-008499 to nVent Electric plc (NVT) (CIK 0001720635) (NVT)
nVent Electric plc (NVT) (CIK 0001720635)
Date: July 26, 2024 · CIK: 0001720635 · Accession: 0000000000-24-008499
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File numbers found in text: 001-38265
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July 26, 2024
Sara E Zawoyski
Chief Financial Officer
nVent Electric plc
The Mille, 1000 Great West Road
8th Floor (East)
London, TW8 9DW, United Kingdom
Re:nVent Electric plc
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed February 20, 2024
Form 8-K
Filed May 3, 2024
File No. 001-38265
Dear Sara E Zawoyski:
We have reviewed your filing and have the following comments.
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 Fiscal Year Ended December 31, 2023
Note 14. Segment Infomation, page 71
1.It appears "Other" is not a reportable segment and should be excluded from your
consolidated reportable segment totals as disclosed in the "Financial information by
reportable segment" tables on page 72. Accordingly, please revise your presentation of
your reportable segments in the tables in accordance with ASC 280. For instance, in the
Segment Income (Loss) table, please revise your presentation of your reportable
segments’ measure of profit or loss and the accompanying reconciliation to comply with
ASC 280-10-50-30(b). In this regard, the required reconciliation should begin with the
total of your reportable segments’ measures of profit or loss (excluding Other) and be
reconciled to your consolidated income before income taxes. Unallocated corporate
expenses and other adjustments should be made after your total reportable segments'
measure of profit or loss. See also ASC 280-10-55-49.
July 26, 2024
Page 2
Form 8-K 2.02 filed May 3, 2022
Exhibit 99.1, page 2
2.We note your disclosure of Segment income on a consolidated basis. Please
note a segment measure of profitability not considered your segment measure of
profitability under ASC 280 is considered a non-GAAP financial measure and subject to
the guidance in Reg G and Item 10(e) of Regulation S-K. In this regard, please reconcile
the differences between the non-GAAP financial measure and the comparable GAAP
measure, tell us how management uses this measure, and revise to disclose why
management believes this measure is useful to investors.
3.We note your reconciliations of non-GAAP measures. Please consider clearly labeling
each measure, such as Net Income - as adjusted, as non-GAAP so that the intent of
these disclosures is clear. Similarly, consider clearly labeling "adjusted EPS" as non-
GAAP. Lastly, please revise to include the disclosures concerning how the non-GAAP
measures are useful to investors and how management uses such measures in accordance
with Item 10(e)(1)(i) of Regulation S-K.
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.
Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at 202-551-3361
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology