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United States securities and exchange commission logo
March 6, 2023
Craig Kesler
Chief Financial Officer
Eagle Materials Inc.
5960 Berkshire Lane, Suite 900
Dallas, Texas 75225
Re: Eagle Materials
Inc.
Form 10-K for the
Fiscal Year Ended March 31, 2022
Filed May 20, 2022
File No. 001-12984
Dear Craig Kesler:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment.
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 apply 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 10-K for the Fiscal Year Ended March 31, 2022
Management Discussion and Analysis of Financial Condition and Results of
Operations
Fiscal Year 2022 vs. Fiscal Year 2021 Results by Segment, page 43
1. We note that you
present net revenue for certain of your segments, which excludes freight
and delivery costs
billed to customers. This appears to be a non-GAAP measure that
would be considered
individually tailored and have the effect of changing the recognition
and measurement
principles applied in accordance with GAAP. Please explain to us how
you considered Question
100.04 of the Non-GAAP Financial Measures Compliance and
Disclosure
Interpretations.
Craig Kesler
FirstName LastNameCraig Kesler
Eagle Materials Inc.
Comapany
March NameEagle Materials Inc.
6, 2023
March2 6, 2023 Page 2
Page
FirstName LastName
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 Eiko Yaoita Pyles, Staff Accountant, at 202-557-3587 or
Melissa
Gilmore, Senior Staff Accountant, at 202-551-3777 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing