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SEC Comment Letter 0000000000-25-009232 to MASIMO CORP (MASI)

MASIMO CORP
Date: Aug. 28, 2025 · CIK: 0000937556 · Accession: 0000000000-25-009232

Financial Reporting Regulatory Compliance Revenue Recognition

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File numbers found in text: 001-33642

Date
August 28, 2025
Author
Micah Young
Form
UPLOAD
Company
MASIMO CORP

Letter

August 28, 2025 Micah Young Executive Vice President, Chief Financial Officer MASIMO CORP 52 Discovery Irvine, CA 92618 Re:MASIMO CORP Item 2.02 Form 8-K filed February 25, 2015 Response dated August 6, 2025 File No. 001-33642 Dear Micah Young: We have reviewed your August 6, 2025 response to our comments 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 our July 24, 2025 oral comments. Item 2.02 Form 8-K Filed February 25, 2025 Exhibit 99.1, page 1 1.We have reviewed your supplemental information letter. We continue to believe that the expenses associated with your consumer products inventory write-downs represent costs that are normal operating costs of your business. Please revise future filings to not include these adjustments to your non-GAAP performance measures. See Question 100.01 of the SEC's Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters.

August 28, 2025 Page 2 Sincerely, Division of Corporation Finance Office of Industrial Applications and Services

Show Raw Text
August 28, 2025
Micah Young
Executive Vice President, Chief Financial Officer
MASIMO CORP
52 Discovery
Irvine, CA 92618
Re:MASIMO CORP
Item 2.02 Form 8-K filed February 25, 2015
Response dated August 6, 2025
File No. 001-33642
Dear Micah Young:
            We have reviewed your August 6, 2025 response to our comments 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 our July 24, 2025 oral
comments.
Item 2.02 Form 8-K Filed February 25, 2025
Exhibit 99.1, page 1
1.We have reviewed your supplemental information letter. We continue to believe that
the expenses associated with your consumer products inventory write-downs represent
costs that are normal operating costs of your business. Please revise future filings to
not include these adjustments to your non-GAAP performance measures. See
Question 100.01 of the SEC's Non-GAAP Financial Measures Compliance and
Disclosure Interpretations.
            Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.

August 28, 2025
Page 2
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services