SEC Comment Letter 0000000000-24-001818 to STAAR SURGICAL CO (STAA) (CIK 0000718937) (STAA)
STAAR SURGICAL CO (STAA) (CIK 0000718937)
Date: Feb. 15, 2024 · CIK: 0000718937 · Accession: 0000000000-24-001818
AI Filing Summary & Sentiment
File numbers found in text: 000-11634
Letter
United States securities and exchange commission logo February 15, 2024 Patrick Williams Chief Financial Officer STAAR Surgical Company 25651 Atlantic Ocean Drive Lake Forest, California 92630 Re:STAAR Surgical Company Form 10-Q for Period Ended September 30, 2023 Form 8-K Filed November 1, 2023 File No. 000-11634 Dear Patrick Williams: We have reviewed your January 31, 2024 response to our comment letter and have the following comments. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our December 6, 2023 letter. Form 8-K Filed November 1, 2023 Exhibit 99.1 1.We note your response to comment 4. It is not clear why you believe the presentation of Adjusted Net Income for ICL provides useful information to investors and how this amount solely relates to ICL products. For example, it appears that sales from other products such IOLs and other surgical products are also included in this amount. It would also appear that the recording of inventory reserves for products would be normal, recurring types of operating expenses incurred in your business; therefore, it remains unclear how you determined it was appropriate to adjust for this amount pursuant to the guidance in Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please advise.
FirstName LastNamePatrick Williams Comapany NameSTAAR Surgical Company February 15, 2024 Page 2 FirstName LastName Patrick Williams STAAR Surgical Company February 15, 2024 Page 2 Please contact Nudrat Salik at 202-551-3692 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
February 15, 2024
Patrick Williams
Chief Financial Officer
STAAR Surgical Company
25651 Atlantic Ocean Drive
Lake Forest, California 92630
Re:STAAR Surgical Company
Form 10-Q for Period Ended September 30, 2023
Form 8-K Filed November 1, 2023
File No. 000-11634
Dear Patrick Williams:
We have reviewed your January 31, 2024 response to our comment letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our December 6,
2023 letter.
Form 8-K Filed November 1, 2023
Exhibit 99.1
1.We note your response to comment 4. It is not clear why you believe the presentation of
Adjusted Net Income for ICL provides useful information to investors and how this
amount solely relates to ICL products. For example, it appears that sales from other
products such IOLs and other surgical products are also included in this amount. It would
also appear that the recording of inventory reserves for products would be normal,
recurring types of operating expenses incurred in your business; therefore, it remains
unclear how you determined it was appropriate to adjust for this amount pursuant to the
guidance in Question 100.01 of the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations. Please advise.
FirstName LastNamePatrick Williams
Comapany NameSTAAR Surgical Company
February 15, 2024 Page 2
FirstName LastName
Patrick Williams
STAAR Surgical Company
February 15, 2024
Page 2
Please contact Nudrat Salik at 202-551-3692 or Terence O'Brien at 202-551-3355 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services