Form 10-K
Please expand your disclosures to explain how the CODM uses operating income, the reported measure of segment profit or loss, in assessing each segment’s performance and deciding how to allocate resources. Refer to the guidance in ASC 280-10-50-29(f) along with the example in ASC 280-10-55-47(bb).
We respectfully acknowledge the Staff’s comment and will enhance our disclosure prospectively, beginning with our Form 10-Q for the quarter ended January 31, 2026 as follows (the use of italics indicates existing disclosures and the use of bold indicates additions):
The CODM uses operating income, as presented in our financial reports, as the primary measure of segment profitability to assess the performance of the segments and make decisions on resource allocation across segments.Read in the reply ↗Rest of the answer
The CODM evaluates segment operating income on a quarterly basis by comparing actual results to forecasted amounts and historical performance. These evaluations, supported by discussions with the leadership team responsible for managing the operations of each reportable segment, are used to assess segment results, monitor operating trends, and support decisions regarding the allocation of resources and consideration of investment opportunities. The Company does not allocate costs from corporate functions to segment operating income. The Company uses the same accounting policies to generate segment results as it does for consolidated results.
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We hope the foregoing answers are responsive to your comments. Please do not hesitate to contact me by email at bandrews@cooperco.com with any questions or comments regarding this correspondence.
First report after the company's reply of 2026-02-05: 10-Q filed 2026-03-06 ↗, against the 10-Q filed 2025-08-28 ↗.
Note 12, Subsequent Events: 31 paragraphs changed; the 3 closest in words to the question are below.
Refer to Note 9. Stockholders' Equity for amounts presented net of the related tax impact in "Accumulated other comprehensive loss."
The Company expects that $( 26.5 ) million recorded as a component of "Accumulated other comprehensive loss" will be realized in the Consolidated Condensed Statements of Income over the next twelve months and the amount will vary depending on prevailing interest rates.
The Company believes the FTT’s decision was incorrect and intends to appeal the FTT’s decision. Although the Company does not believe that a loss is probable, an adverse outcome is reasonably possible. Depending on the results of the appeal, the Company could prevail on some or all of the issues in dispute, which could result in an obligation to pay a portion or all of the assessed amounts, with an estimated loss ranging from £ 0 to £ 71.7 million, plus accrued interest.
Paragraphs where only numbers, dates or period words changed are not shown. Cut words struck through, new words highlighted and underlined.
Also in this review: closing letter, 2026-02-12