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United States securities and exchange commission logo
December 13, 2021
Jorge M. Gomez
Executive Vice President & Chief Financial Officer
Dentsply Sirona Inc.
13320 Ballantyne Corporate Place
Charlotte, NC 28277-36077
Re: Dentsply Sirona
Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed March 1, 2021
File No. 000-16211
Dear Mr. Gomez:
We have reviewed your filing 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, 2020
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 43
1. We note you attribute a
decline in sales volume, in part, to certain countries in Asia and
that there other
references in your filing to China. We also note on page 87 that
geographic information
represents revenues for shipments made by operating businesses
located in the country
or territory identified, including export sales, and that this
disclosure does not
include any information related to Asia or China. Please describe to us
and revise disclosure
in future filings to include discussion and analysis in quantitative
and qualitative terms
related to your revenues that are attributable to China pursuant to
Item 303 of Regulation
S-K, or explain to us why additional disclosure is not required. In
addition, please
explain to us whether there are any material concentrations of revenues
included in "other
foreign" net sales in Note 5 to your financial statements and describe to
us in further detail
your methodology for attributing revenues from external customers to
Jorge M. Gomez
Dentsply Sirona Inc.
December 13, 2021
Page 2
individual countries. Refer to ASC 280-10-50-41.
Consolidated Financial Statements
Revenue Recognition, page 75
2. Please revise future filings to include all of the disclosures
required by ASC 606-10-50, as
applicable. For example, provide the qualitative and quantitative
disclosure about the
significant judgments and changes in judgments, including inputs and
assumptions,
related to your accounting for returns, rebates and discounts, as set
forth in ASC 606-10-
50-1(b), 50-17, and 50-20, a description of the payment terms under
50-12, and
disaggregated revenue under 50-5.
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 Michael Fay at 202-551-3812 or Brian Cascio, Accounting
Branch
Chief, at 202-551-3676 if you have any questions.
FirstName LastNameJorge M. Gomez Sincerely,
Comapany NameDentsply Sirona Inc.
Division of
Corporation Finance
December 13, 2021 Page 2 Office of Life
Sciences
FirstName LastName