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TEXT-EXTRACT
2
filename2.txt
September 7, 2018
Paul W. Graves
President and Chief Executive Officer
Livent Corporation
c/o FMC Corporation
2929 Walnut Street
Philadelphia, PA 19104
Re: Livent Corporation
Registration Statement on Form S-1
Filed August 27, 2018
File No. 333-227026
Dear Mr. Graves:
We have reviewed your registration statement and have the following
comment. Please
respond to this letter by amending your registration statement and providing
the requested
information. If you do not believe our comment applies to your facts and
circumstances or do
not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the
information you
provide in response to this comment, we may have additional comments.
Form S-1 Filed August 27, 2018
Financial Statements for the Year Ended December 31, 2017
Combined Statements of Operations, page F-3
1. You disclose on page F-44 that you adopted ASU No. 2017-07 in the first
quarter of 2018,
and as a result, you have reclassified "Non-operating pension expense and
settlement
charges" out of "Income from operations before interest expense, net and
income taxes"
and into "Income from operations before income taxes." Given that the
amendments in
ASU No. 2017-07 should be applied retrospectively for the presentation of
the service
cost component and the other components of net periodic pension cost and
net periodic
postretirement benefit cost in the income statement, it is not clear why
you continue to
present "Non-operating pension expense and settlement charges" within
"Income from
operations before interest expense, net and income taxes" for the two
years ended
December 31, 2017 on page F-3. Please advise or revise accordingly.
Paul W. Graves
Livent Corporation
September 7, 2018
Page 2
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
You may contact Jeff Gordon (Staff Accountant) at 202-551-3866 or John
Cash
(Accounting Branch Chief) at 202-551-3768 if you have questions regarding
comments on the
financial statements and related matters. Please contact Frank Pigott (Staff
Attorney) at 202-
551-3570 or Jay Ingram (Legal Branch Chief) at 202-551-3397 with any other
questions.
Sincerely,
FirstName LastNamePaul W. Graves Division of
Corporation Finance
Office of
Manufacturing and
Comapany NameLivent Corporation
Construction
September 7, 2018 Page 2
cc: Michael Kaplan
FirstName LastName
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