SEC Comment Letter 0000000000-23-011566 to HARMONIC INC (HLIT) (CIK 0000851310) (HLIT)
HARMONIC INC (HLIT) (CIK 0000851310)
Date: Oct. 23, 2023 · CIK: 0000851310 · Accession: 0000000000-23-011566
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File numbers found in text: 000-25826
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United States securities and exchange commission logo
October 23, 2023
Walter Jankovic
Chief Financial Officer
Harmonic Inc.
2590 Orchard Parkway
San Jose, CA 95131
Re:Harmonic Inc.
Form 10-K for the fiscal year ended December 31, 2022
Filed February 28, 2023
File No. 000-25826
Dear Walter Jankovic:
We have reviewed your October 4, 2023 response to our comment letter and have the
following comment.
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 August 29,
2023 letter.
Form 10-K for the fiscal year ended December 31, 2022
Notes to Consolidated Financial Statements
Note 4: Revenue, page 60
1.We note your response to prior comment 5. Your disclosures on page 36 indicate that the
"Appliance and integration" revenue category "includes hardware, licenses and
professional services" and that the "SaaS and service" revenue category "includes usage
fees for our SaaS platform and support services." We further note that management makes
several references to hardware, software, and SaaS revenues during the second quarter
2023 earnings call. Please tell us your consideration of separately disclosing revenues
related to your hardware, software, and service offerings or similar categories. In doing so,
identify all specific revenues categories regularly provided to your chief operating
decision maker. In addition to ASC 606-10-50-5 and ASC 606-10-55-89 through 55-91,
also see ASC 280-10-50-40.
FirstName LastNameWalter Jankovic
Comapany NameHarmonic Inc.
October 23, 2023 Page 2
FirstName LastName
Walter Jankovic
Harmonic Inc.
October 23, 2023
Page 2
Please contact Eiko Yaoita Pyles at 202-551-3587 or Andrew Blume at 202-551-3254 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing