May 18, 2022
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, N.E.
Washington, D.C. 20549
Re: Benchmark Electronics, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Filed February 25, 2022
File No. 001-10560
Ladies and Gentlemen:
The following information and comments are made in reply to the staff of the Securities and Exchange Commission’s (the “Staff”) letter dated May 5, 2022 (the “Second Comment Letter”) to Benchmark Electronics, Inc. (the “Company”), relating to the Company’s Annual Report on Form 10-K for the year ended December 31, 2021 (the “Form 10-K”). With regard to the specific points communicated to the Company in the Second Comment Letter, we hereby submit the following responses.
Consolidated Statements of Income, page 41
Response 2: The Company appreciates the opportunity to clarify the nature of its business with the Staff. Consistent with our telephonic discussion on May 12, 2022, the Company operates its business in the electronic manufacturing services (EMS) industry, providing integrated services to original equipment manufacturers (OEMs) as our customers. The Company predominantly derives revenue from its manufacturing services and technology solutions, which involve the sale of manufactured products built to customer specifications. The Company also derives revenue from design and engineering services in support of the manufacturing services. However, the Company’s design and engineering services and technology solutions represented, on a combined basis, less than 10% of the Company’s consolidated revenue for each of the years 2021, 2020 and 2019.
As a general matter, the Company’s manufacturing service arrangements with customers are documented through a master services agreement, which outlines the general terms and conditions of the particular engagement, and a specific purchase commitment from the customer. Consequently, the revenue streams from manufacturing services as well as design and engineering services and technology solutions (which represented less than 10% of the Company’s consolidated revenue as noted above), are categorized and presented in a single line item on the face of the statements of income.
Notes to the Financial Statements
Note 13 – Segment and Geographic Information, page 61
Response 2: The Company advises the Staff that the corporate expenses not allocated to reportable segments are primarily general and administrative expenses, such as corporate employee payroll and benefit costs, for corporate functions and corporate facility costs. Corporate functions include legal, finance, tax, treasury, information technology, risk management, human resources, business development and other administrative functions. The Company respectfully acknowledges the Staff’s comment and will revise its future filings to include such disclosure regarding the nature of the items included in corporate expenses not allocated to reportable segments.
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Thank you for your assistance. If you have any questions or further comments, please contact me at (623) 300-7066.
| Sincerely, | |
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| Benchmark Electronics, Inc. | |
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| By: /s/ Roop K. Lakkaraju | |
| Roop K. Lakkaraju | |
| EVP and Chief Financial Officer | |
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cc: | Jeffrey Benck, President & Chief Executive Officer, Benchmark Electronics, Inc. | |
| Stephen Beaver, SVP and General Counsel, Benchmark Electronics, Inc. | |
| KPMG LLP Jeffrey E. Beck and Kevin Zen, Snell & Wilmer L.L.P. | |
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