United States securities and exchange commission logo
May 13, 2020
Barry Litwin
President and Chief Executive Officer
Systemax Inc.
11 Harbor Park Drive
Port Washington, New York 11050
Re: Systemax Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed March 13,
2020
File No. 1-13792
Dear Mr. Litwin:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Highlights from 2019 , page 22
1. Please tell us your
consideration of disclosing the increase in average daily sales on a
GAAP basis and
describing the process for calculating sales and the average daily sales
increase on a constant
currency basis.
Notes to Consolidated Financial Statements
4. REVENUE, page 55
2. Please explain to us
why you believe presenting disaggregated revenue by geography
most reasonably depicts
how the nature, amount, timing, and uncertainty of revenue and
cash flows are affected
by economic and industry factors based on the guidance in ASC
606-10-55-89 through
55-91. In this regard we note that your discussion and analysis of
results of operations
refers to mixed results with continued strength in key categories
Barry Litwin
Systemax Inc.
May 13, 2020
Page 2
where you are making investments in your offering and subject matter
expertise, to
softness in the heating products category in the fourth quarter as a
result the mild winter
weather and the sales growth in Canada, which accounted for 4%-5% of
sales. In
addition, please tell us your consideration of whether providing
disaggregated revenue on
a product or customer basis better depicts how the nature, amount,
timing, and uncertainty
of revenue and cash flows are affected by economic and industry
factors. Please note that
more than one type of category may be needed to meet the objective in
ASC 606-10-50-5
for disaggregating revenue. Finally, please tell us how you considered
the disclosure
requirements of ASC 280-10-50-40, revenue information for each product
and service or
each group of similar products and services.
In closing, 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.
You may contact Scott Stringer at 202-551-3272 or me at 202-551-3344
with any
questions.
FirstName LastNameBarry Litwin Sincerely,
Comapany NameSystemax Inc.
Division of
Corporation Finance
May 13, 2020 Page 2 Office of Trade &
Services
FirstName LastName