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The Effect of SEC’s Comment Letters on the Comparability of Non-GAAP Earnings

附錄二、非公認盈餘相關之監管信函

使用非公認盈餘衡量相關名稱之實例
公司：Air Products and Chemicals, Inc.
公司提交之文件及其提交之日期：8-K，2016 年 1 月 29 日

監管信函發佈之日期：2016 年 2 月 26 日
全文網址： https://www.sec.gov/Archives/edgar/data/2969/000000000016066442/

filename1.pdf

Dear Mr. Crocco:
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 8-K Filed on January 29, 2016
1. In your earnings release, we note you provide disclosures that you identify as
“EPS”, “Net Income”, “Operating Income”, and “EPS Guidance” that actually
relate to non- GAAP financial measures. Please revise future disclosures related

to non-GAAP financial measures to not use GAAP terminology when you refer to
non-GAAP financial measures.

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