STANLEY BLACK & DECKER, INC. responded to SEC staff comments on non-GAAP measures
Letter dated
2025-04-29; published on EDGAR 2026-08-25 — the
SEC releases comment letters only after the review closes.
We note from the tables on page 33 and 34 that you are making non-GAAP adjustments to income taxes on continuing operations. Please revise to include disclosure on how this adjustment has been calculated or determined. See Question 102.11 of the SEC Staff’s C&DI on Non-GAAP Financial Measures. The Company acknowledges the Staff’s comment and advises the Staff that the income taxes attributable to its Non-GAAP…
Evidence
Direction
company to staff
Letter dated
2025-04-29
Published on edgar
2026-08-25
Reviewing
Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 28, 2024 Form 8-K furnished on February 5, 2025 File No. 001-05224 Dear Ms. Erlanger and Mr.
Source
Company response to SEC staff (CORRESP)
Topics
MD&A, Non-GAAP measures, Income taxes, Inventory, Goodwill and impairment, Segment reporting
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
STANLEY BLACK & DECKER, INC. responded to SEC staff comments on inventory
Letter dated
2025-05-21; published on EDGAR 2026-08-25 — the
SEC releases comment letters only after the review closes.
We note from your response to prior comment 2, that in 2024, the footprint rationalization adjustment includes $45.2m of costs related to the transformation or reconfiguration of other sites within your manufacturing and distribution network. You also state that these costs primarily related to inventory transfer costs and engineering and information technology costs to re-configure the operations, processes…
Evidence
Direction
company to staff
Letter dated
2025-05-21
Published on edgar
2026-08-25
Reviewing
Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 28, 2024 Form 10-Q for the Quarter Ended March 29, 2025 Response Letter dated April 29, 2025
Source
Company response to SEC staff (CORRESP)
Topics
MD&A, Inventory, Non-GAAP measures
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
STANLEY BLACK & DECKER, INC. responded to SEC staff comments on inventory
Letter dated
2025-08-06; published on EDGAR 2026-08-25 — the
SEC releases comment letters only after the review closes.
We note from your response to our prior comment 2 that the closure of the Ft. Worth site and related inventory and tooling charges were a result of your inability to fully ramp production using new automation technology and equipment. As a result, the inventory and tooling were no longer viable or usable elsewhere in the Company’s operations. Please tell us more about the decision to close the Ft. Worth plant…
Evidence
Direction
company to staff
Letter dated
2025-08-06
Published on edgar
2026-08-25
Reviewing
Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 28, 2024 Form 10-Q for the Quarter Ended March 29, 2025 Response Letter dated May 21, 2025 Fi
Source
Company response to SEC staff (CORRESP)
Topics
MD&A, Inventory
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
STANLEY BLACK & DECKER, INC. responded to SEC staff comments on non-GAAP measures
Letter dated
2025-09-09; published on EDGAR 2026-08-25 — the
SEC releases comment letters only after the review closes.
We note your response to our prior comment, and continue to believe that the adjustment to your non-GAAP financial measures for the write-off of inventory related to the closure of the Ft. Worth site is not appropriate as those costs represent normal, recurring costs of operations. See Question 100.01 in the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Please revise future filings…
Evidence
Direction
company to staff
Letter dated
2025-09-09
Published on edgar
2026-08-25
Reviewing
Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 28, 2024 Form 10-Q for the Quarter Ended March 29, 2025 Response Letter dated August 6, 2025
Source
Company response to SEC staff (CORRESP)
Topics
MD&A, Non-GAAP measures, Inventory
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
SEC staff questioned STANLEY BLACK & DECKER, INC.'s accounting for non-GAAP measures
Letter dated
2025-04-01; published on EDGAR 2026-08-25 — the
SEC releases comment letters only after the review closes.
We note from the tables on page 33 and 34 that you are making non-GAAP adjustments to income taxes on continuing operations. Please revise to include disclosure on how this adjustment has been calculated or determined. See Question 102.11 of the SEC Staff’s C&DI on Non-GAAP Financial Measures. We note from footnote (1) at the top of page 35, that the adjustment for “footprint rationalization” costs in 2024 primarily…
Evidence
Direction
staff to company
Letter dated
2025-04-01
Published on edgar
2026-08-25
Reviewing
Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 28, 2024 Form 8-K furnished on February 5, 2025 File No. 001-05224 Dear Patrick Hallinan: We
Source
SEC staff comment letter (UPLOAD)
Topics
MD&A, Non-GAAP measures, Income taxes, Goodwill and impairment, Inventory, Segment reporting
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
SEC staff questioned STANLEY BLACK & DECKER, INC.'s accounting for inventory
Letter dated
2025-05-07; published on EDGAR 2026-08-25 — the
SEC releases comment letters only after the review closes.
We note from your response to prior comment 2, that in 2024, the footprint rationalization adjustment includes $45.2m of costs related to the transformation or re- configuration of other sites within your manufacturing and distribution network. You also state that these costs primarily related to inventory transfer costs and engineering and information technology costs to re-configure the operations, processes…
Evidence
Direction
staff to company
Letter dated
2025-05-07
Published on edgar
2026-08-25
Reviewing
Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 28, 2024 Form 10-Q for the Quarter Ended March 29, 2025 Response Letter dated April 29, 2025
Source
SEC staff comment letter (UPLOAD)
Topics
MD&A, Inventory, Non-GAAP measures
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
SEC staff questioned STANLEY BLACK & DECKER, INC.'s accounting for inventory
Letter dated
2025-07-10; published on EDGAR 2026-08-25 — the
SEC releases comment letters only after the review closes.
We note from your response to our prior comment 2 that the closure of the Ft. Worth site and related inventory and tooling charges were a result of your inability to fully ramp production using new automation technology and equipment. As a result, the inventory and tooling were no longer viable or usable elsewhere in the Company’s operations. Please tell us more about the decision to close the Ft. Worth plant…
Evidence
Direction
staff to company
Letter dated
2025-07-10
Published on edgar
2026-08-25
Reviewing
Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 28, 2024 Form 10-Q for the Quarter Ended March 29, 2025 Response Letter dated May 21, 2025 Fi
Source
SEC staff comment letter (UPLOAD)
Topics
MD&A, Inventory
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.
SEC staff questioned STANLEY BLACK & DECKER, INC.'s accounting for non-GAAP measures
Letter dated
2025-08-26; published on EDGAR 2026-08-25 — the
SEC releases comment letters only after the review closes.
We note your response to our prior comment, and continue to believe that the adjustment to your non-GAAP financial measures for the write-off of inventory related to the closure of the Ft. Worth site is not appropriate as those costs represent normal, recurring costs of operations. See Question 100.01 in the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Please revise future filings…
Evidence
Direction
staff to company
Letter dated
2025-08-26
Published on edgar
2026-08-25
Reviewing
Stanley Black & Decker, Inc. Form 10-K for the Year Ended December 28, 2024 Form 10-Q for the Quarter Ended March 29, 2025 Response Letter dated August 6, 2025
Source
SEC staff comment letter (UPLOAD)
Topics
MD&A, Non-GAAP measures, Inventory
Why
SEC staff reviewed the company's periodic report and raised written comments on its accounting, or the company replied to them. Letters are published on EDGAR only after the review closes.