March 3, 2026
Division of Corporation Finance
Office of Industrial Applications and Services
United States Securities and Exchange Commission
Washington, D.C. 20549
Re: Cabot Corporation
Form 10-K filed November 24, 2025
File No. 001-05667
Dear Ms. Baker and Mr. O’Brien:
This letter is being submitted in response to the Staff’s comment letter on February 19, 2026 regarding Cabot Corporation’s Annual Report on Form 10-K for the fiscal year ended September 30, 2025. For ease of reference, we have restated the Staff’s comment before our response below.
Form 10-K for the Year Ended September 30, 2025
Management’s Discussion and Analysis
Results of Operations
Definition of Terms and Non-GAAP Financial Measures, page 30
As noted on page 31, your non-GAAP measure, total segment EBIT, excludes unallocated corporate overhead expenses, such as certain corporate salaries and headquarters expenses, plus costs related to special projects and initiatives. As such, this non-GAAP measure appears to exclude normal, recurring, cash operating expenses and may therefore not comply with Rule 100(b) of Regulation G and Item 10(e) of Regulation S-K. With specific reference to Question 100.01 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures, please confirm you will revise future filings, including earnings releases filed under Form 8-K, to eliminate this measure.
Cabot Response:
We understand the Staff’s comment and acknowledge the guidance in Question 100.01 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. In future filings, as well as our earnings releases furnished on Current Reports on Form 8-K, we will eliminate the disclosure of total segment EBIT.