United States securities and exchange commission logo
July 16, 2020
William Sperry
Chief Financial Officer
HUBBELL INC
40 Waterview Drive
Shelton CT 06484
Re: HUBBELL INC
Form 10-K for
Fiscal Year Ended December 31, 2019
Filed February 14,
2020
File No. 001-02958
Dear Mr. Sperry:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2019
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Adjusted Operating Measures, page 21
1. We note your adjusted
measures exclude amortization of intangible assets associated with
business acquisitions.
Please expand your disclosures in all future filings to more fully
address the following:
Describe what
amortization is being excluded from the measures [all amortization,
step up], explain
why it is being excluded, and identify the specific asset or assets the
exclusions relate
to.
Explain why you
believe the measures are useful. We note you refer to core
operations;
however, it is not clear why you exclude amortization of intangible assets
on that basis since
the measures include revenue from core operations generated, in
part, by acquired
intangible assets.
Describe the
limitations of the measures and clearly state that although amortization
William Sperry
HUBBELL INC
July 16, 2020
Page 2
for intangible assets is being excluded, revenue generated, in
part, from related assets
is not being excluded.
2. In your reconciliations related to adjusted net income, we note you
present adjustments,
net of tax. Please revise your reconciliations in all future filings
to reflect the impact of
income taxes as a separate adjustment and to explain how the tax
impact is calculated.
Refer to Question 102.11 of the updated Compliance & Disclosure
Interpretations on
Non-GAAP Financial Measures.
3. We note your Results of Operations discussion refers to the term
"organic" in the context
of net sales growth and volumes. It appears your measure "organic net
sales" represents
a non-GAAP financial measure and it is unclear how the measure is
determined,
particularly what the measure excludes. Please expand your disclosure
in all future
filings to clearly describe your definition of "organic net sales" and
provide all the
information required by Item 10(e) of Regulation S-K.
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.
You may contact Kevin Stertzel at (202) 551-3723 or Anne McConnell at
(202) 551-
3709 with any questions.
FirstName LastNameWilliam Sperry Sincerely,
Comapany NameHUBBELL INC
Division of
Corporation Finance
July 16, 2020 Page 2 Office of
Manufacturing
FirstName LastName
