SEC Comment Letter for Concentrix Corp (CNXC) (CIK 0001803599) (CNXC) — Jul 31, 2020
Concentrix Corp (CNXC) (CIK 0001803599)
Date: July 31, 2020 · CIK: 0001803599 · Accession: 0000000000-20-007011
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United States securities and exchange commission logo July 31, 2020 Christopher Caldwell Chief Executive Officer Concentrix Corp 44111 Nobel Drive Fremont, CA 94538 Re:Concentrix Corp Amendment No. 2 to Draft Registration Statement on Form 10 Submitted on July 15, 2020 CIK No. 0001803599 Dear Mr. Caldwell: We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 2 to Draft Registration Statement on Form 10 Management's Discussion and Analysis of Financial Condition and Results of Operations, page 1.We reviewed your response and revisions in response to comment 4. It is inappropriate to merely combine information for the pre-and post-transaction periods without reflecting all relevant pro forma adjustments required by S-X Article 11. Please revise.
FirstName LastNameChristopher Caldwell Comapany NameConcentrix Corp July 31, 2020 Page 2 FirstName LastName Christopher Caldwell Concentrix Corp July 31, 2020 Page 2 You may contact Adam Phippen at (202) 551-3336 or Lyn Shenk at (202) 551-3380 if you have questions regarding comments on the financial statements and related matters. Please contact Daniel Morris at (202) 551-3314 or Mara Ransom at (202) 551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Allison Leopold Tilley, Esq.
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United States securities and exchange commission logo
July 31, 2020
Christopher Caldwell
Chief Executive Officer
Concentrix Corp
44111 Nobel Drive
Fremont, CA 94538
Re:Concentrix Corp
Amendment No. 2 to Draft Registration Statement on Form 10
Submitted on July 15, 2020
CIK No. 0001803599
Dear Mr. Caldwell:
We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form 10
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
53
1.We reviewed your response and revisions in response to comment 4. It is inappropriate to
merely combine information for the pre-and post-transaction periods without reflecting all
relevant pro forma adjustments required by S-X Article 11. Please revise.
FirstName LastNameChristopher Caldwell
Comapany NameConcentrix Corp
July 31, 2020 Page 2
FirstName LastName
Christopher Caldwell
Concentrix Corp
July 31, 2020
Page 2
You may contact Adam Phippen at (202) 551-3336 or Lyn Shenk at (202) 551-3380 if
you have questions regarding comments on the financial statements and related matters. Please
contact Daniel Morris at (202) 551-3314 or Mara Ransom at (202) 551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Allison Leopold Tilley, Esq.