SRSEC Reporting Desk

NOV Inc. (NOV) – SEC staff letter

2026-03-18 · Re: Form 10-K for the Fiscal Year ended December 31, 2025 Filed February 12, 2026 · Accession 0000000000-26-002765 · 2 staff comment(s) issued

Company response(s): 2026-03-27

Segment Reporting (ASC 280)

2026-03-18 · Form 10-K for the Fiscal Year ended December 31, 2025 Filed February 12, 2026 · Comment 1 · Note 16 - Business Segments and Geographic Areas, page 81 Agreed to revise
Staff comment: We note that you include two tables on page 83 having various segment details, including one with "Pre-tax Other Items," which are described in footnote (2) to the other table and included in various line items of the other table. Please modify your disclosures as necessary to clarify which line items within the other table represent the significant expense categories and amounts that are regularly provided to your CODM, which you are disclosing pursuant to FASB ASC 280-10-50-26A. Please explain to us how you considered the distinction made by the FASB in establishing the disclosure requirements for significant expense categories in FASB ASC 280-10-50-26A, and the disclosure requirements… letter →
Company response: The Company acknowledges the Staff’s comment regarding the presentation of segment expense disclosures and the distinction between significant expense categories under ASC 280-10-50-26A and other segment items under ASC 280-10-50-26B. The Company’s Chief Operating Decision Maker (“ CODM ”), identified as the Chief Executive Officer, evaluates segment performance primarily based on operating profit, and is regularly provided with certain expense information, including cost of revenue, selling, general and administrative expenses, depreciation and amortization, impairments of goodwill and long-lived assets, and gain/loss on sales of fixed assets. These expense measures reflect the primary… response letter →
Segment Reporting (ASC 280)
2026-03-18 · Form 10-K for the Fiscal Year ended December 31, 2025 Filed February 12, 2026 · Comment 2 · determined to be other than significant expense categories, if this is your view. Responded
Staff comment: We note that you have limited disclosures pertaining to revenues under this heading to revenue from external customers and intersegment revenues based on FASB ASC 280- 10-50-22, and revenues by four geographical areas based on FASB ASC 280-10-50-41. We also note that you report revenues on page 76 for the categories of services and rentals, sales of shorter-lived capital equipment, sales of consumable products, sales of long-lived capital equipment, and aftermarket sales and services. However, on page 3 you indicate that you manufacture a diverse line of products and on pages 4 through 6, you identify about 17 product and service offerings in describing your reportable operating segments.… letter →
Company response: The Company respectfully acknowledges the Staff’s comment regarding the level of revenue disaggregation. The Company’s current disclosures include revenues from external customers and intersegment revenues for each reportable segment in accordance with ASC 280-10-50-22, as well as revenues by geographic area in accordance with ASC 280-10-50-41. The Company also considered the requirements of ASC 280-10-50-40, which requires disclosure of revenues for each product and service, or each group of similar products and services. In applying this guidance, the Company evaluated whether its product and service offerings represent distinct groupings with materially different characteristics and also… response letter →
Segment Reporting (ASC 280)

Full letter on EDGAR → · Filing index · All NOV Inc. (NOV) correspondence

Segment Reporting (ASC 280) – what to check: Check ASU 2023-07 significant segment expense disclosure, CODM identification, and that MD&A segment discussion matches the ASC 280 note.

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