April 2, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, N.E.
Washington, D.C. 20549
Attention: Jeffrey Gordon and Jean Yu
| Re: | Commercial Metals Company |
| Form 8-K Filed January 8, 2024 |
| Response dated March 14, 2024 |
| File No. 001-04304 |
Ladies and Gentlemen:
This letter sets forth the response of Commercial Metals Company (the “Company”) to the comment of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated March 19, 2024, with respect to the above-referenced filing and the Company’s response letter dated March 14, 2024. For your convenience, the Staff’s comment is set forth in bold below, followed by the response of the Company.
Form 8-K Filed January 8, 2024
Exhibit No. 99.1, page 12
| 2. | Please refer to prior comment 2 of our letter dated February 29, 2024. Based on your March 14, 2024 response, mill operational commissioning costs appear to be normal operating expenses necessary to operate your business. As such, the adjustment to your non-GAAP financial measures for these costs appears to be inconsistent with Question 100.01 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Please revise your presentations in future filings to remove this adjustment from your non-GAAP financial measures. |
Response: The Company respectfully acknowledges the Staff’s comment. In future filings and releases, the Company will limit the information provided to only a discussion of the costs incurred and will not include adjustments for “Mill operational commissioning costs” in its non-GAAP financial measures in any period presented.
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