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United States securities and exchange commission logo
March 29, 2022
Lori Lipcaman
Chief Financial Officer
Vishay Intertechnology, Inc.
63 Lancaster Avenue
Malvern, Pennsylvania 19355-2143
Re: Vishay
Intertechnology, Inc.
Form 10-K for the
Year Ended December 31, 2021
Filed February 23,
2022
File No. 001-07416
Dear Ms. Lipcaman:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we may ask
you to provide us
with information so we may better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for the Year Ended December 31, 2021
Financial Statements
Notes to Consolidated Financial Statements
Note 15 Segment and Geographic Data, page F-45
1. We note your
presentation of more than one profit measure for each of your reportable
segments: gross profit
and segment operating income. We further note that you consider
segment operating
income to be the more important metric. ASC 280-10-50-22 requires
disclosure of a single
measure of segment profit and ASC 280-10-50-28 indicates that
when more than one
segment profit measure is utilized the one with the measurement
principles most
consistent with GAAP becomes the segment measure of profit or loss.
Please revise all
applicable disclosures within your filing to present only that single
measure of segment
profit or loss for each segment and reconcile to your consolidated
income measure as
required by ASC 280-10-50-30b. In addition, please note that
additional segment
profit or loss measures may be presented outside of your financial
Lori Lipcaman
Vishay Intertechnology, Inc.
March 29, 2022
Page 2
statements and footnotes as non-GAAP measures.
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 Heather Clark at 202-551-3624 or Kevin Woody at
202-551-3629 with
any questions.
FirstName LastNameLori Lipcaman Sincerely,
Comapany NameVishay Intertechnology, Inc.
Division of
Corporation Finance
March 29, 2022 Page 2 Office of
Manufacturing
FirstName LastName