View:
United States securities and exchange commission logo
October 12, 2023
Joseph Reitmeier
Chief Financial Officer
Lennox International Inc.
2140 Lake Park Blvd.
Richardson, Texas 75080
Re: Lennox
International Inc.
Form 10-K For
Fiscal Year Ended December 31, 2022
Response Dated
September 28, 2023
File No. 001-15149
Dear Joseph Reitmeier:
We have reviewed your September 28, 2023 response to our comment
letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our August 31, 2023
letter.
Response Dated September 28, 2023
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
17
1. We note your response
to prior comment 2. Please further address the following:
Your response
acknowledges that some customers may prefer products that meet
certain emissions
or other environmental standards. Tell us more about what you
have experienced in
this regard, including the extent to which you have been or
expect to be
affected by the emissions reduction targets of your primary customers.
Joseph Reitmeier
Lennox International Inc.
October 12, 2023
Page 2
Explain how you determine whether the changes in demand and
competition you
have observed are related to climate change, as compared to the
other factors noted in
your response, and how you assess these changes, providing
support for your
materiality determination.
Your response states that you are working to develop
products and brands that have
a reduced impact on climate change. Clarify whether your
development work is
related to the changes in demand and competition you have
observed, and tell us how
you considered disclosing this as a climate-related business
trend.
Tell us more about the energy from alternative energy sources
used in your
operations and explain how this relates to the indirect
consequences you considered.
Provide support for your evaluation of materiality regarding
increased demand for
energy from alternative energy sources, including quantification
of related costs for
each of the periods covered by your Form 10-K and expected to be
incurred in future
periods.
We note your proposed amended disclosure regarding reputational
risks due to our
products consuming energy or using refrigerants and
hydrofluocarbons. Tell us how
you considered disclosing reputational risks related to your
operations, in addition to
your products.
2. We note your response to prior comment 3. Please tell us how you
considered providing
disclosure regarding the potential for the physical effects of climate
change to affect your
operations and results, for instance in relation to the risks
discussed in your Form 10-K
under the caption Our Ability to Meet Customer Demand may be
Limited by Our Single-
Location Production Facilities, Reliance on Certain Key Suppliers and
Unanticipated
Significant Shifts in Customer Demand.
3. We note your response to prior comment 3 regarding insurance. Please
quantify for us the
cost of insurance for each of the periods covered by your Form 10-K.
Clarify how the
upward trend in the costs of insurance noted in your response,
including in relation to any
weather-related impacts, has affected your expectations for insurance
costs and
availability. Explain whether and how your use of self-insurance is
related to the cost and
availability of insurance affected by extreme weather events.
Please contact Charli Gibbs-Tabler at 202-551-6388 or Jennifer Angelini
at 202-551-
3047 with any other questions.
FirstName LastNameJoseph Reitmeier Sincerely,
Comapany NameLennox International Inc.
Division of
Corporation Finance
October 12, 2023 Page 2
FirstName LastName
Office of
Technology