SEC Comment Letter for ChampionX Holding Inc. (CIK 0001789542) — Apr 27, 2020
ChampionX Holding Inc. (CIK 0001789542)
Date: April 27, 2020 · CIK: 0001789542 · Accession: 0000000000-20-003565
AI Filing Summary & Sentiment
File numbers found in text: 333-236380
Letter
United States securities and exchange commission logo April 27, 2020 Deric D. Bryant Chief Executive Officer ChampionX Holding Inc. c/o Ecolab Inc. 1 Ecolab Place St. Paul, MN 55102 Re:ChampionX Holding Inc. Amendment No. 2 to Registration Statement on Form S-4 Filed April 17, 2020 File No. 333-236380 Dear Mr. Bryant: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this comment, we may have additional comments. Amendment No. 2 to Registration Statement on Form S-4 Information about Apergy, page 84 1.We note the use of the capitalized term "Net Promoter Score" in this section. Please explain what the Net Promoter Score (NPS) measures, how it was calculated, what your NPS was in the Kimberlite Oilfield Research survey, and why it is significant to your business. You may contact Christie Wong at 202-551-3684 or Al Pavot at 202-551-3738 if you have questions regarding comments on the financial statements and related matters. Please contact Ada D. Sarmento at 202-551-3798 or Mary Beth Breslin at 202-551-3625 with any other questions.
FirstName LastNameDeric D. Bryant Comapany NameChampionX Holding Inc. April 27, 2020 Page 2 FirstName LastName Deric D. Bryant ChampionX Holding Inc. April 27, 2020 Page 2 Sincerely, Division of Corporation Finance Office of Life Sciences cc: Charles W. Mulaney, Jr., Esq.
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United States securities and exchange commission logo
April 27, 2020
Deric D. Bryant
Chief Executive Officer
ChampionX Holding Inc.
c/o Ecolab Inc.
1 Ecolab Place
St. Paul, MN 55102
Re:ChampionX Holding Inc.
Amendment No. 2 to Registration Statement on Form S-4
Filed April 17, 2020
File No. 333-236380
Dear Mr. Bryant:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments.
Amendment No. 2 to Registration Statement on Form S-4
Information about Apergy, page 84
1.We note the use of the capitalized term "Net Promoter Score" in this section. Please
explain what the Net Promoter Score (NPS) measures, how it was calculated, what your
NPS was in the Kimberlite Oilfield Research survey, and why it is significant to your
business.
You may contact Christie Wong at 202-551-3684 or Al Pavot at 202-551-3738 if you
have questions regarding comments on the financial statements and related matters. Please
contact Ada D. Sarmento at 202-551-3798 or Mary Beth Breslin at 202-551-3625 with any other
questions.
FirstName LastNameDeric D. Bryant
Comapany NameChampionX Holding Inc.
April 27, 2020 Page 2
FirstName LastName
Deric D. Bryant
ChampionX Holding Inc.
April 27, 2020
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Charles W. Mulaney, Jr., Esq.