SRSEC Reporting Desk

CABOT CORP (CBT) – Company response

2026-03-03 · Re: oration Form 10-K filed November 24, 2025 · Accession 0001193125-26-087544 · Agreed to revise

Responds to staff letter of 2026-02-19.

Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & UsefulnessSegment Reporting (ASC 280)

2026-02-19 · Form 10-K filed November 24, 2025 · Comment 1 · Definition of Terms and Non-GAAP Financial Measures, page 30 Agreed to revise
Staff comment: 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… letter →
Company response: 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… response letter →
Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & UsefulnessSegment Reporting (ASC 280)

Full letter on EDGAR → · Filing index · All CABOT CORP (CBT) correspondence

Non-GAAP: Adjustments & Labels – what to check: Do not exclude normal, recurring cash operating expenses or use individually tailored recognition methods; label measures clearly (C&DI 100.01–100.04).

Non-GAAP: Reconciliation & Usefulness – what to check: Reconcile every non-GAAP measure (including segment-level measures presented outside the ASC 280 note) to the most directly comparable GAAP measure, and explain why it is useful.

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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