SEC Comment Letter 0000000000-23-007546 to WOLFSPEED, INC. (WOLF)
WOLFSPEED, INC.
Date: July 14, 2023 · CIK: 0000895419 · Accession: 0000000000-23-007546
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-40863
Referenced dates: March 10, 2023, May 10, 2023
Letter
United States securities and exchange commission logo July 14, 2023 Neill P. Reynolds Executive Vice President and Chief Financial Officer Wolfspeed, Inc. 4600 Silicon Drive Durham, North Carolina 27703 Re:Wolfspeed, Inc. Form 10-K for the Fiscal Year Ended June 26, 2022 Filed August 22, 2022 Form 8-K Filed January 25, 2023 File No. 001-40863 Dear Neill P. Reynolds: We have reviewed your responses to our comment letters dated May 10, 2023 and March 10, 2023 and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. 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 applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 10, 2023 letter. Form 8-K Filed January 25, 2023 Exhibit 99.1, page 7 1.Please refer to prior comment 5 of our letter dated March 10, 2023. Based on your March 24, 2023 response, factory start-up costs and underutilization costs appear to be normal operating expenses necessary to operate your business. As such, the adjustments to your non-GAAP financial measures for these costs are inconsistent with Question 100.01 of the Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Please revise your presentations in future filings to remove these adjustments.
FirstName LastNameNeill P. Reynolds Comapany NameWolfspeed, Inc. July 14, 2023 Page 2 FirstName LastName Neill P. Reynolds Wolfspeed, Inc. July 14, 2023 Page 2 You may contact Jeffrey Gordon at 202-551-3866 or Martin James at 202-551-3671 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
Show Raw Text
United States securities and exchange commission logo
July 14, 2023
Neill P. Reynolds
Executive Vice President and Chief Financial Officer
Wolfspeed, Inc.
4600 Silicon Drive
Durham, North Carolina 27703
Re:Wolfspeed, Inc.
Form 10-K for the Fiscal Year Ended June 26, 2022
Filed August 22, 2022
Form 8-K Filed January 25, 2023
File No. 001-40863
Dear Neill P. Reynolds:
We have reviewed your responses to our comment letters dated May 10, 2023 and March
10, 2023 and have the following comment. In our comment, we may ask you to provide us with
information so we may better understand your disclosure.
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 applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
March 10, 2023 letter.
Form 8-K Filed January 25, 2023
Exhibit 99.1, page 7
1.Please refer to prior comment 5 of our letter dated March 10, 2023. Based on your March
24, 2023 response, factory start-up costs and underutilization costs appear to be normal
operating expenses necessary to operate your business. As such, the adjustments to your
non-GAAP financial measures for these costs are inconsistent with Question 100.01 of the
Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Please
revise your presentations in future filings to remove these adjustments.
FirstName LastNameNeill P. Reynolds
Comapany NameWolfspeed, Inc.
July 14, 2023 Page 2
FirstName LastName
Neill P. Reynolds
Wolfspeed, Inc.
July 14, 2023
Page 2
You may contact Jeffrey Gordon at 202-551-3866 or Martin James at 202-551-3671 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing