July 17, 2019
Jeffrey Andreson
President and Chief Financial Officer
Ichor Holdings, Ltd.
3185 Laurelview Court
Fremont, CA. 94538
Re: Ichor Holdings, Ltd.
Form 10-K for the Fiscal Year Ended December 28, 2018
Filed March 8, 2019
Form 8-K Filed May 7, 2019
File No. 001-37961
Dear Mr. Andreson:
We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In some of our comments, 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 8-K Filed May 7, 2019
U.S. GAAP and Non-GAAP Summary Consolidated Statements of Operations, page 9
1. We note that you present a full non-GAAP income statement on page 9 of your Earnings Release, a presentation that appears to give more prominence to the non-GAAP measures and is inconsistent with Question 102.10 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016. Please review this guidance when preparing your next filing.
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.
Jeffrey Andreson
Ichor Holdings, Ltd.
July 17, 2019
You may contact Julie Sherman, Staff Accountant, at (202) 551-3640 or
Brian Cascio,
Accounting Branch Chief, at (202) 551-3676 with any questions.
FirstName LastNameJeffrey Andreson Sincerely,
Comapany NameIchor Holdings, Ltd.
Division of
Corporation Finance
July 17, 2019 Page 2 Office of Electronics
and Machinery
FirstName LastName
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