SEC Comment Letter 0000000000-23-009089 to Livent Corp. (CIK 0001742924)
Livent Corp. (CIK 0001742924)
Date: Aug. 21, 2023 · CIK: 0001742924 · Accession: 0000000000-23-009089
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File numbers found in text: 001-38694
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United States securities and exchange commission logo
August 21, 2023
Paul W. Graves
Chief Executive Officer
Livent Corp.
1818 Market Street
Philadelphia, Pennsylvania 19103
Re:Livent Corp.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed February 24, 2023
Form 8-K Dated August 3, 2023
Filed August 3, 2023
File No. 001-38694
Dear Paul W. Graves:
We have limited our review of your filing to the financial statements and related
disclosures and 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 business days by providing the requested
information or advise 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 to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Managements Discussion and Analysis of Financial Condition and Results of Operations, page
53
1.We see that your revenue in 2022 increased by approximately 93%, or $392.8 million,
versus $420.4 million for 2021 primarily due to higher pricing across all of your products
partially offset by a slight decrease in sales volumes. We also note similar general
explanations of the increase in revenues in your 10-Qs. Where changes in financial
statement line items are the result of several factors, each significant factor should be
separately quantified and discussed. Please provide an expanded disclosure covering the
material variances reflected in your 2022 and 2023 financial statements including
revenues, gross margin percentages, and effective tax rates. Disclose also the impact of
foreign exchange rate variances on each account that was materially impacted. The
FirstName LastNamePaul W. Graves
Comapany NameLivent Corp.
August 21, 2023 Page 2
FirstName LastName
Paul W. Graves
Livent Corp.
August 21, 2023
Page 2
disclosure should identify the specific changes ocuuring during the period that materially
impacted the corresponding revenue and expense accounts. It appears that your disclosure
should address each factor identified on pages 23-24 unless the corresponding impact on
your operating results was immaterial. See the relevant guidance in Item 303(b) of
Regulation S-K and Section 501.12 of the Financial Reporting Codification.
Note 5, page 72
2.Please disclose what has been deducted in presenting the "inventory, net" balance. Any
allowance account should be separately presented if material.
Form 8-K filed August 3, 2023
Exhibit 99.1, page 5
3.It appears that you are deducting a cash settled item in your adjusted cash provided by
operations liquidity measure. Please clarify how you are compliant with Item
10(e)(1)(ii)(A) of Regulation S-K.
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.
You may contact Julie Sherman at (202) 551-3640 or Al Pavot at (202) 551-3738 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services