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United States securities and exchange commission logo
April 13, 2023
Gregory S. Lovins
Chief Financial Officer
Avery Dennison Corporation
8080 Norton Parkway
Mentor, OH 44060
Re: Avery Dennison
Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2022
Filed February 22,
2023
File No. 001-07685
Dear Gregory S. Lovins:
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, 2022
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Financial Measures, page 21
1. Refer to your
discussion of free cash flow and similarly in your earnings releases and 10-
Q filings. Given that
free cash flow is typically calculated as cash from operating
activities as presented
in the statement of cash flows under GAAP, less capital
expenditures, please
revise the title of these measures to something similar to
``Adjusted Free Cash
Flow to alert your investors that it has been adjusted from the
measure typically
referred to as ``Free Cash Flow. Please refer to Question No. 102.07
of the Compliance &
Disclosure Interpretations ("C&DIs") on Non-GAAP Financial
Measures, updated
December 13, 2022.
Gregory S. Lovins
FirstName LastNameGregory
Avery Dennison Corporation S. Lovins
Comapany
April NameAvery Dennison Corporation
13, 2023
April 213, 2023 Page 2
Page
FirstName LastName
Note 1. Summary of Significant Accounting Policies
Revenue Recognition, page 48
2. Please expand your revenue recognition policy to discuss how and when
revenue for your
specific products within your two reportable segments is recognized.
For example,
disclose for which products and services revenue is recognized at a
point in time and those
that are recognized over time, including the input measures used in
recognizing the
revenue. Disclose when control of your products or services is
transferred to the
customer, along with the related performance obligations. Your current
disclosure in the
first paragraph is general in nature, and should be expanded or
tailored to be specific to
the nature of the products and services you provide. For example, we
note your Materials
Group segment manufactures and sells pressure-sensitive label
materials and performance
tapes products, brand graphics and reflective products, whereas your
Solutions Group
segment offers RFID solutions, branding and embellishment solutions,
data management
and identification solutions, etc. as disclosed in the Business
section and also in Note 15.
Please revise your disclosures accordingly. Refer to ASC 606-10-25-14
through 25-18
and ASC 606-10-50-12.
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 Beverly Singleton at (202) 551-3328 or Melissa Gilmore at
(202) 551-
3777 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing