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United States securities and exchange commission logo
April 24, 2023
William Sperry
Chief Financial Officer
HUBBELL INC
40 Waterview Drive
Shelton, CT 06484
Re: HUBBELL INC
Form 10-K for the
Fiscal Year Ended December 31, 2022
Filed, February 9,
2023
File No. 001-02958
Dear William 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 the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Adjusted Operating Measures, page 23
1. We note your
reconciliations of adjusted operating measures on page 24 appear to
essentially provide a
non-GAAP income statement as they include most of the line items
and subtotals presented
on your GAAP income statement. Please explain to us how you
determined the current
format is appropriate and complies with Question 102.10 of the
Division of Corporation
Finance's Compliance & Disclosure Interpretations on Non-
GAAP Financial Measures
or tell us how you plan to modify it in future filings, so as not
to give undue
prominence to the non-GAAP financial measures presented.
2022 Compared to 2021, page 25
2. It appears to us your
current disclosures related to multiple financial statement line items
are similar and do not
adequately quantify the factors you identify or explain the
William Sperry
HUBBELL INC
April 24, 2023
Page 2
underlying reasons for changes, including if and how the changes could
impact future
results. Please revise your disclosures in future annual and quarterly
filings to more fully
address the following:
When you disclose and discuss multiple factors that impact your
results, quantify the
impact of the factors you identify, for example, we note you
identify multiple and
offsetting factors that impacted consolidated net sales, net sales
by segment, cost of
goods sold, gross profit, operating income, and operating income
by segment;
In regard to consolidated net sales and net sales by segment,
quantify the impact of
favorable price realization and higher unit volumes and disclose
and discuss the
reasons for changes;
In regard to cost of goods sold, gross profit, operating income,
and operating income
by segment, quantify the impact of favorable price realization and
higher costs and
disclose and discuss the reasons for changes; and
In regard to the Utility Solutions segment, more fully explain the
facts and
circumstances related to the commercial resolution and disclose
the impact.
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
April 24, 2023 Page 2 Office of
Manufacturing
FirstName LastName