MOHAWK INDUSTRIES INC (MHK)
CIK 851968 · EDGAR correspondence
| Date | Company | Type | Outcome | Issues |
|---|---|---|---|---|
| 2026-01-27 | MOHAWK INDUSTRIES INC (MHK) | SEC staff letter | Review completed (no further comments) | |
| 2026-01-13 | MOHAWK INDUSTRIES INC (MHK) | Company response | Agreed to revise | Segment Reporting (ASC 280)MD&A: Results & Known TrendsGoodwill & Asset ImpairmentFair Value & InvestmentsAuditor & Audit ReportCapitalization, Equity & Escrow |
| 2025-12-19 | MOHAWK INDUSTRIES INC (MHK) | SEC staff letter | 4 staff comment(s) issued | Segment Reporting (ASC 280)MD&A: Results & Known TrendsGoodwill & Asset ImpairmentFair Value & InvestmentsAuditor & Audit ReportCapitalization, Equity & Escrow |
Comments & responses
2025-12-19 · Form 10-K for the fiscal year ended December 31, 2024 Filed February 20, 2025 · Comment 1 · Critical Accounting Policies, page 33 Responded
Staff comment: We note that you recorded material goodwill and intangible asset impairment charges in prior periods. We also note that the assessment of goodwill for impairment is identified by your auditor as a critical audit matter in their audit report. Based on the continued materiality of goodwill and intangible assets to your financial statements, underlying negative operating trends, and the fact that your net book value exceeds your market capitalization, please more fully explain to us how you determined the estimated fair values of your reporting units exceed their carrying values. In addition, to the extent you conclude an impairment charge that could materially impact your financial statements… letter →
Company response: As described in Critical Accounting Policies in the Company’s Form 10-K for the fiscal year ended December 31, 2024, the Company has identified Global Ceramic, Flooring North America (“Flooring NA”) and Flooring Rest of the World (“Flooring ROW”) as its reporting units for the purposes of allocating goodwill as well as assessing impairments. As of the Company’s 2024 annual goodwill impairment testing date, which was the first day of the fourth quarter of 2024 (the “2024 Annual Impairment Test Date”), the Company completed quantitative goodwill impairment tests (the “Annual Impairment Tests”) and determined that the estimated fair values of its reporting units with goodwill exceeded their… response letter →
2025-12-19 · Form 10-K for the fiscal year ended December 31, 2024 Filed February 20, 2025 · Comment 2 · (17) Segment Reporting, page 76 Agreed to revise
Staff comment: We note you present both gross profit (loss) and operating income (loss). Please clearly identify the measure or measures of a segment’s profit or loss that the chief operating decision maker uses in assessing segment performance and deciding how to allocate resources. If the CODM uses more than one measure of a segment’s profit or loss in assessing segment performance and deciding how to allocate resources, disclose the measure required to be reported, which is the measure that management believes is determined in accordance with the measurement principles most consistent with those used in measuring the corresponding amounts in the consolidated financial statements. For each measure of a… letter →
Company response: The Company respectfully acknowledges the Staff’s comment and explains that while segment Gross profit (loss) is included in the financial information that is provided to the CODM for informational purposes, the CODM does not use segment Gross profit (loss) when assessing performance and allocating resources. The CODM uses the segment Operating income (loss) to allocate resources and assess performance. Therefore, the Company believes it is the metric required to be disclosed under the guidance in ASC 280-10-50-28A. In future filings, the Company plans to present only this required measure. To address the Staff’s comment and limit confusion on the metric used by the CODM in future filings,… response letter →
2025-12-19 · Form 10-K for the fiscal year ended December 31, 2024 Filed February 20, 2025 · Comment 3 · 50-29(f) and 55-47(bb). Agreed to revise
Staff comment: We note you disclose selling, general and administrative expenses by segment. Please tell us whether any other significant segment expenses are regularly provided to the CODM or easily computable from information that is regularly provided to the CODM. In particular, tell us your consideration of presenting cost of sales by segment, which is easily computable from gross profit and net sales. In addition, for each reportable segment, disclose an amount for other segment items, along with a description of the composition of other segment items. Refer to ASC 280-10-50-26A, 50-26B and 55-15B. letter →
Company response: The Company respectfully acknowledges the Staff’s comment and confirms that the only segment expense information regularly provided to the CODM is segment Selling, general and administrative expenses. However, as both segment Net sales and segment Gross profit (loss) are also regularly provided to the CODM, segment Cost of sales is significant and easily computable from information regularly provided to the CODM. In future filings, the Company will include disclosure of segment Cost of sales in accordance with the guidance in ASC 280-10-50-26A and 55-15B. Please see the response to Comment 4 below for an illustrative example of future planned disclosures. Further, in accordance with… response letter →
2025-12-19 · Form 10-K for the fiscal year ended December 31, 2024 Filed February 20, 2025 · Comment 4 · Page 3 Agreed to revise
Staff comment: Please provide reconciliations of the totals of your reportable segments' measures of profit or loss to your consolidated income before income taxes, in accordance with ASC 280-10-50-28C and 50-30(b). letter →
Company response: The Company respectfully acknowledges the Staff’s comment and confirms, as discussed above, that the only measure of segment profit/loss used by the CODM to assess performance and allocate resources is segment Operating income (loss). In future filings, beginning with the Form 10-K for the fiscal year ended December 31, 2025, the Company will update its segment disclosures and proposes to include a reconciliation of segment Operating income (loss) to consolidated Earnings (loss) before income taxes in accordance with ASC 280-10-50-28C and 50-30(b). For illustrative purposes, the following is an example of the updated segment disclosure using amounts for the year ended December 31, 2024 ($… response letter →
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