United States securities and exchange commission logo
March 19, 2024
Paul J. Lawrence
Senior Vice President and Chief Financial Officer
Commercial Metals Company
6565 N. MacArthur Blvd.
Irving, TX 75039
Re: Commercial Metals
Company
Form 8-K Filed
January 8, 2024
Response dated
March 14, 2024
File No. 001-04304
Dear Paul J. Lawrence:
We have reviewed your March 14, 2024 response to our comment
letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our February 29,
2024 letter.
Form 8-K Filed January 8, 2024
Exhibit No. 99.1, page 12
1. Please refer to prior
comment 2 of our letter dated February 29, 2024. Based on your
March 14, 2024
response, mill operational commissioning costs appear to be normal
operating expenses
necessary to operate your business. As such, the adjustment to your
non-GAAP financial
measures for these costs appears to be inconsistent with Question
100.01 of the
Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures. Please revise
your presentations in future filings to remove this adjustment
from your non-GAAP
financial measures.
Paul J. Lawrence
FirstName
CommercialLastNamePaul J. Lawrence
Metals Company
Comapany
March NameCommercial Metals Company
19, 2024
March2 19, 2024 Page 2
Page
FirstName LastName
Please contact Jeffrey Gordon at 202-551-3866 or Jean Yu at 202-551-3305
if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing