October 18, 2019
Catherine Suever
Chief Financial Officer
PARKER HANNIFIN CORP
6035 Parkland Blvd.
Cleveland, OH 44124
Re: PARKER HANNIFIN CORP
Form 10-K for the fiscal year ended June 30, 2019
Filed August 23, 2019
Form 8-K filed August 1, 2019
File No. 1-04982
Dear Ms. Suever:
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 June 30, 2019
Critical Accounting Policies
Impairment of Goodwill and Long-Lived Assets, page 27
1. We note that you test goodwill for impairment at the reporting unit
level, which is
equivalent to your operating segments. Please revise future disclosures
to address the
following:
Identify the number of reporting units, or operating segments, where
goodwill is
allocated and tested for impairment;
Indicate whether fair value substantially exceeds book value for all
reporting units,
and;
If the fair value of any reporting unit does not substantially exceed
book
please identify the reporting unit and quantify the goodwill
associated with that
reporting unit.
Catherine Suever
PARKER HANNIFIN CORP
October 18, 2019
Page 2
Form 8-K Filed on August 1, 2019
Exhibit 99.1
2. We note your presentation of non-GAAP diluted adjustments to calculate
the non-GAAP
measure, Adjusted Earnings per Diluted Share, on a prospective (2020)
and historical
(2019) basis. However, adding back adjustments net of tax is
inconsistent with Question
102.11 in the updated Compliance and Disclosure Interpretations (April
4, 2018). Please
revise future presentations accordingly to comply with this comment in
your non-GAAP
presentations in Item 2.02 of your Form 8-K.
3. In future filings please reconcile EBITDA to Net Income as presented
on the face of the
income statement. Please refer to Question 103.02 in the updated
Compliance and
Disclosure Interpretations.
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 Mindy Hooker, Accountant, at 202-551-3732 or John Cash,
Branch
Chief, at 202-551-3768 with any questions.
FirstName LastNameCatherine Suever Sincerely,
Comapany NamePARKER HANNIFIN CORP
Division of
Corporation Finance
October 18, 2019 Page 2 Office of
Manufacturing
FirstName LastName