United States securities and exchange commission logo
April 5, 2024
Heinrich Jonker
Interim Chief Financial Officer
Astec Industries, Inc.
1725 Shepherd Road
Chattanooga, TN 37421
Re: Astec Industries,
Inc.
Form 10-K for the
Year Ended December 31, 2023
Filed February 28,
2024
File No. 001-11595
Dear Heinrich Jonker:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
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.
Form 10-K for the Year Ended December 31, 2023
Note 19. Operations by Industry Segment and Geographic Area, page 72
1. Pursuant to ASC
280-10-50-30(b), revise your segment presentation to provide a total for
your reportable
segments' measure of profit or loss and reconcile such total to income
before income taxes.
Please note that your "Corporate and Other" category presented
under ASC 280-10-50-15
does not represent a reportable segment and should be excluded
from the reportable
segment total.
2. Remove all disclosures
of the non-GAAP measure you identify as the Company total
"Segment Operating
Adjusted EBITDA" and delete the reconciliation of this non-GAAP
measure appearing on
page 73 of your GAAP financial statements.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Heinrich Jonker
Astec Industries, Inc.
April 5, 2024
Page 2
Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage
at 202-551-
3361 with any questions.
FirstName LastNameHeinrich Jonker Sincerely,
Comapany NameAstec Industries, Inc.
Division of
Corporation Finance
April 5, 2024 Page 2 Office of Technology
FirstName LastName