SRSEC Reporting Desk

COOPER COMPANIES, INC. (COO) – Company response

2026-02-05 · Re: The Responses to Letter dated January 27, 2026 Form 10-K for Fiscal Year Ended October 31, 2025 Filed December 5, 2025 · Accession 0001628280-26-005711 · Agreed to revise

Responds to staff letter of 2026-01-27.

Segment Reporting (ASC 280)

2026-01-27 · Form 10-K for Fiscal Year Ended October 31, 2025 Filed December 05, 2025 · Comment 1 · Note 12. Business Segment Information, page 85 Agreed to revise
Staff comment: Please expand your disclosures to explain how the CODM uses operating income, the reported measure of segment profit or loss, in assessing each segment’s performance and deciding how to allocate resources. Refer to the guidance in ASC 280-10-50-29(f) along with the example in ASC 280-10-55-47(bb). letter →
Company response: We respectfully acknowledge the Staff’s comment and will enhance our disclosure prospectively, beginning with our Form 10-Q for the quarter ended January 31, 2026 as follows (the use of italics indicates existing disclosures and the use of bold indicates additions): The CODM uses operating income, as presented in our financial reports, as the primary measure of segment profitability to assess the performance of the segments and make decisions on resource allocation across segments. The CODM evaluates segment operating income on a quarterly basis by comparing actual results to forecasted amounts and historical performance. These evaluations, supported by discussions with the leadership team… response letter →
Segment Reporting (ASC 280)

Full letter on EDGAR → · Filing index · All COOPER COMPANIES, INC. (COO) 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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