IEXIDEX Corporation

We see that you present Adjusted Operating Margin, Adjusted EPS, Free Cash Flow, Adjusted Net Income and Adjusted EBITDA on the first page of your earnings release without also presenting the comparable GAAP measures with equal or greater prominence, as required by Item 10(e)(1)(i)(A) of Regulation S-K, which is inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016.

Rest of the question

Please review that guidance when preparing future earnings releases.

In future earnings releases, the Company will present comparable GAAP measures with equal or greater prominence if non-GAAP measures are used to supplement our GAAP measures. In future earnings releases in which we present Adjusted Operating Margin, Adjusted EPS, Free Cash Flow, Adjusted Net Income and/or Adjusted EBITDA or any combination of non-GAAP measures, we will precede these disclosures with a greater or equally prominent disclosure of comparable GAAP measures.

Rest of the answer

In addition, our discussion and analysis will include a similar discussion of the comparable GAAP measures in a location with equal or greater prominence. Finally, we will also include comparable GAAP measures in our earnings release headlines if and when non-GAAP measures are also presented.

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We see you present the non-GAAP measure Free Cash Flows in the highlights section of your earnings release without also presenting the comparable GAAP measures with equal or greater prominence, which is inconsistent with Question 102.10 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016. Please review that guidance when preparing future earnings releases.

Rest of the question

See also Item 10(e)(1)(i)(A) of Regulation S-K.

In future earnings releases, if the Company presents Free Cash Flow in the highlights section, we will also include Operating Cash Flow with equal or greater prominence. Additionally, if we present other non-GAAP measures in the highlights section of our future earnings releases we will include the most comparable GAAP measure with equal or greater prominence. Read in the reply ↗

Revise future earnings releases to clearly define your use of the term “organic.”

In our next earnings release, the Company will define the term organic as “sales and orders calculated according to generally accepted accounting principles in the United States excluding amounts from acquired or divested businesses during the first twelve months after acquisition or divestiture and the impact of foreign currency translation.” Read in the reply ↗

We note that in Table 2 of your earnings release you reconcile segment EBITDA to segment operating income and not to net income, which is inconsistent with the guidance in Question 103.02 of the Updated Compliance and Disclosure interpretations issued on May 17, 2016. Please review that guidance when preparing your future filings and earnings releases.

The reconciliation in Table 2 of segment EBITDA to segment operating income, rather than net income, was presented due to the fact that we do not allocate consolidated interest expense or consolidated provision for income taxes to our segments. However, in our next earnings release, we will modify our reconciliation as follows such that segment EBITDA is reconciled to the Company’s consolidated net income.

Three months ended March 31, 2016

FMT

HST

FSDP

Corporate Office

Total IDEX

Operating income (loss)

$ 51,401

$ 40,699

$ 25,404

$ (14,947)

$ 102,557

Other income (expense) -

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net

167

373

114

744

Depreciation and amortization

7,256

10,861

1,482

358

19,957

EBITDA

$ 58,824

$ 51,933

$ 26,976

$ (14,475)

$ 123,258

Interest expense

(10,489)

Provision for income taxes

(24,682)

(19,957)

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Please refer to the table presented on the final page of your earnings release. In future earnings releases provide a reconciliation of the net sales and operating income segment amounts presented in this table to the consolidated amounts in your statements of operations.

In our next earnings release, we will add the additional information within “Corporate office and other” to the table so that amounts reconcile to our consolidated statements of operations. Additionally, the reconciliation in response #4 will be included in the tables in our future earnings releases such that net sales and operating income (loss) are reconciled to the consolidated amounts in our statements of operations.

Three Months Ended

March 31,

2016

2015

Fluid & Metering Technologies

Net sales

$ 218,248

Operating income

51,401

55,898

Operating margin

24.3

25.6

$

Rest of the answer

63,061

27.8

28.9

$ 7,256

$ 6,361

Capital expenditures

3,290

4,969

Health & Science Technologies

$ 179,120

40,699

37,457

21.8

20.9

$ 47,796

27.9

26.7

$ 10,861

$ 10,208

4,137

2,885

Fire & Safety/Diversified Products

$ 106,622

25,404

27,162

25.5

$ 29,556

25.8

27.7

$ 1,482

$ 1,532

1,107

1,322

Corporate office and other

Intersegment sales eliminations

$ (1,792)

(14,947)

(18,760)

(14,475)

(18,423)

409

116

901

Company

$ 502,198

102,557

101,757

20.4

20.3

$ 121,990

24.5

$ 19,957

$ 18,510

8,650

10,077

In connection with providing its responses to the Staff’s comments, the Company acknowledges the following:

•

The Company is responsible for the adequacy and accuracy of the disclosure in the filings;

Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

The Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

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