Correspondence 0001104659-25-111480 from MASIMO CORP (MASI)
MASIMO CORP
Date: Nov. 13, 2025 · CIK: 0000937556 · Accession: 0001104659-25-111480
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-33642
Letter
VIA EDGAR SUBMISSION Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549
Re: Masimo Corporation Item 2.02 Form 8-K filed February 25, 2025 Response dated August 6, 2025 File No. 001-33642
Dear Ms. Baker and Mr. O'Brien:
On behalf of our client Masimo Corporation (the " Company " or " Masimo "), a Delaware corporation, we thank you for the letter, dated August 28, 2025, from the staff (the " Staff ") of the Securities and Exchange Commission (the " Commission "), with respect to the correspondence captioned above. The Staff's comment is repeated below in bold, followed by the Company's response.
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 ("CD&I").
The Company respectfully acknowledges the Staff's comment and, although the Company believes that its consumer products inventory write-down adjustments were appropriate and complied with Question 100.01 of the SEC's Non-GAAP Financial Measures CD&I, the Company confirms that it has presented its non-GAAP performance measures for periods beginning with the quarter ended September 27, 2025 without such inventory write-down adjustments. In addition, prior period presentations have been conformed to the current presentation (i.e., without such inventory write down adjustment). The following excerpt of the non-GAAP reconciliation tables from the Company's most recent Form 8-K filed with the Commission on November 4, 2025, reflects this new presentation, and the related footnote indicates the nature of the prior adjustments and states that such adjustments are no longer being made to the Company's non-GAAP measures.
* * *
We thank the Staff for the time and attention it has dedicated to this matter. If you have any questions, please call me at (212) 763-1818.
Very truly yours,
/s/ Richard Brand
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November 13, 2025
VIA
EDGAR SUBMISSION
Jeanne Baker and Terrence O'Brien
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re:
Masimo Corporation
Item 2.02 Form 8-K filed February 25, 2025
Response dated August 6, 2025
File No. 001-33642
Dear Ms. Baker and Mr. O'Brien:
On behalf of our client Masimo Corporation (the " Company "
or " Masimo "), a Delaware corporation, we thank you for the letter, dated August 28, 2025, from the staff (the " Staff ")
of the Securities and Exchange Commission (the " Commission "), with respect to the correspondence captioned above. The
Staff's comment is repeated below in bold, followed by the Company's response.
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 ("CD&I").
The Company respectfully acknowledges the Staff's comment and,
although the Company believes that its consumer products inventory write-down adjustments were appropriate and complied with Question
100.01 of the SEC's Non-GAAP Financial Measures CD&I, the Company confirms that it has presented its non-GAAP performance measures
for periods beginning with the quarter ended September 27, 2025 without such inventory write-down adjustments. In addition, prior period
presentations have been conformed to the current presentation (i.e., without such inventory write down adjustment). The following excerpt
of the non-GAAP reconciliation tables from the Company's most recent Form 8-K filed with the Commission on November 4, 2025, reflects
this new presentation, and the related footnote indicates the nature of the prior adjustments and states that such adjustments are no
longer being made to the Company's non-GAAP measures.
* * *
We thank the Staff for the time and attention it has dedicated to this
matter. If you have any questions, please call me at (212) 763-1818.
Very truly yours,
/s/ Richard Brand
Richard Brand
cc: Micah Young, Chief Financial Officer
Masimo Corporation