Correspondence 0001213900-24-101628 from Ads-Tec Energy Public Ltd Co (ADSE)
Ads-Tec Energy Public Ltd Co
Date: Nov. 22, 2024 · CIK: 0001879248 · Accession: 0001213900-24-101628
AI Filing Summary & Sentiment
File numbers found in text: 001-41188
Referenced dates: October 15, 2024
Letter
Ads-Tec Energy Public Limited Company
10 Earlsfort Terrace
Dublin 2, D02 T380, Ireland
November 22, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attention: Division of Corporation Finance
Office of Manufacturing
Re:
Ads-Tec Energy Public Limited Company
Form 20-F for the Fiscal Year Ended December 31, 2023
Response Letter Dated October 15, 2024
File No. 001-41188
Ladies and Gentlemen:
On behalf of Ads-Tec Energy Public Limited Company (the “Company”), I am pleased to submit this letter in response to the written comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) received on November 19, 2024 (the “Comment Letter”) to the above-referenced Annual Report on Form 20-F filed with the Commission by the Company on April 30, 2024 and the Response Letter dated October 15, 2024.
To assist your review, set forth below in bold are the comments of the Staff contained in the Comment Letter. Immediately below each reproduced comment is the response of the Company with respect thereto.
Response Letter Dated October 15, 2024
Company Response to Staff Comment 1, page 1
1. We note your response to prior comment 1. Please remove the adjustments for provision for an onerous contract and write-down on inventories from your non-IFRS measures as such amounts appear to be normal, recurring operating expenses necessary to operate your business per Question 100.01 of the SEC Staff’s C&DI on Non-GAAP Financial Measures.
Response: The Company respectfully acknowledges the Staff’s comment and appreciates the Staff’s continued attention to this matter. After further consideration, the Company advises the Staff that, in future filings, the Company will no longer include adjustments for provision for an onerous contract and write-down on inventories in the Company’s non-IFRS measures.
Please contact me at +49 7022 2522 1480 if I can be of further assistance.
Very truly yours,
Ads-Tec Energy Public Limited Company
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Ads-Tec Energy Public Limited Company
10 Earlsfort Terrace
Dublin 2, D02 T380, Ireland
November 22, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Attention:
Division of Corporation Finance
Office of Manufacturing
Re:
Ads-Tec Energy Public Limited Company
Form 20-F for the Fiscal Year Ended December 31, 2023
Response Letter Dated October 15, 2024
File No. 001-41188
Ladies and Gentlemen:
On behalf of Ads-Tec Energy
Public Limited Company (the “Company”), I am pleased to submit this letter in response to the written comments
of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) received
on November 19, 2024 (the “Comment Letter”) to the above-referenced Annual Report on Form 20-F filed with the
Commission by the Company on April 30, 2024 and the Response Letter dated October 15, 2024.
To assist your review, set
forth below in bold are the comments of the Staff contained in the Comment Letter. Immediately below each reproduced comment is the response
of the Company with respect thereto.
Response Letter Dated October 15, 2024
Company Response to Staff Comment 1, page 1
1.
We note your response to prior comment 1. Please remove the adjustments for provision for an onerous contract and write-down on inventories from your non-IFRS measures as such amounts appear to be normal, recurring operating expenses necessary to operate your business per Question 100.01 of the SEC Staff’s C&DI on Non-GAAP Financial Measures.
Response: The Company respectfully acknowledges
the Staff’s comment and appreciates the Staff’s continued attention to this matter. After further consideration, the Company
advises the Staff that, in future filings, the Company will no longer include adjustments for provision for an onerous contract and write-down
on inventories in the Company’s non-IFRS measures.
Please contact me at +49 7022 2522 1480 if I can
be of further assistance.
Very truly yours,
Ads-Tec Energy Public Limited Company
By:
/s/ Stefan Berndt-von Buelow
Name:
Stefan Berndt-von Buelow
Title:
Chief Financial Officer
cc:
Lynwood E. Reinhardt, Reed Smith LLP
Michael S. Lee, Reed Smith LLP