MTDMettler Toledo

We note that you presented an annual effective tax rate for 2017 that excludes the onetime charge associated with the Tax Cuts and Jobs Act but you did not identify the measure as non-GAAP or include any of the disclosures required by Item 10(e)(1)(i) of Regulation S-K. Please revise your presentation in future filings to fully comply with that guidance.

We acknowledge the Staff's comments and will revise our presentation to eliminate the use of this non-GAAP measure in future filings. Read in the reply ↗

We note you present non-GAAP measures more prominently than the directly comparable GAAP measures by including the identification of only non-GAAP adjusted EPS in the headline, discussing non-GAAP local currency sales growth before GAAP sales growth, and discussing destination local currency sales growth and adjusted operating income without the most directly comparable GAAP measure.

Rest of the question

In addition, you present the forward looking non-GAAP measures local currency sales growth and Adjusted EPS without providing the reconciliation of the amounts to the most directly comparable GAAP financial measure or the statement that providing such reconciliation requires unreasonable efforts. Refer to Question 102.10 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures and please revise your presentation in future earnings releases to comply with that guidance.

We acknowledge the Staff's comments and will ensure that our presentation in future earnings releases complies with the guidance in Question 102.10 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Read in the reply ↗

Your computation of free cash flow differs from the typical calculation, which is cash flows from operating activities as presented in the statement of cash flows under GAAP less capital expenditures by excluding restructuring payments. Please revise the title of this non-GAAP measure so it is not confused with free cash flow as typically calculated.

Rest of the question

See Question 102.07 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

We acknowledge the Staff's comment and will refer to "adjusted free cash flow" in future presentations.

Mettler-Toledo acknowledges that it is responsible for the adequacy and accuracy of disclosure in its filings, notwithstanding any review, comments, action or absence of action by the staff. Read in the reply ↗