SEC Comment Letter 0000000000-24-004498 to INSEEGO CORP. (INSG)
INSEEGO CORP.
Date: April 23, 2024 · CIK: 0001022652 · Accession: 0000000000-24-004498
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38358
Letter
United States securities and exchange commission logo April 23, 2024 Steven Gatoff Chief Financial Officer Inseego Corp. 9710 Scranton Road, Suite 200 San Diego, CA 92121 Re:Inseego Corp. Form 10-K for the Fiscal Year Ended December 31, 2023 Form 8-K filed February 21, 2024 Response dated April 17, 2024 File No. 001-38358 Dear Steven Gatoff: We have reviewed your April 17, 2024 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 April 9, 2024 letter. Form 8-K filed on February 21, 2024 Exhibit 99.1 1.We have reviewed your response to prior comment 2. It appears to us that managing inventory levels is an integral aspect of your business; as such, it continues to appear to us your non-GAAP adjustments for "inventory adjustment - E&O and contract manufacturer liability" and "write-off of capitalized inventory fees" represent normal operating expenses necessary to operate your business and are not consistent with the guidance in Question 100.01 of the Division of Corporation Finance's Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Please revise future filings to no longer exclude these adjustments from any non-GAAP performance measure.
FirstName LastNameSteven Gatoff Comapany NameInseego Corp. April 23, 2024 Page 2 FirstName LastName Steven Gatoff Inseego Corp. April 23, 2024 Page 2 Please contact Jeff Gordon at 202-551-3866 or Anne McConnell at 202-551-3709 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
April 23, 2024
Steven Gatoff
Chief Financial Officer
Inseego Corp.
9710 Scranton Road, Suite 200
San Diego, CA 92121
Re:Inseego Corp.
Form 10-K for the Fiscal Year Ended December 31, 2023
Form 8-K filed February 21, 2024
Response dated April 17, 2024
File No. 001-38358
Dear Steven Gatoff:
We have reviewed your April 17, 2024 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 April 9, 2024 letter.
Form 8-K filed on February 21, 2024
Exhibit 99.1
1.We have reviewed your response to prior comment 2. It appears to us that managing
inventory levels is an integral aspect of your business; as such, it continues to appear to us
your non-GAAP adjustments for "inventory adjustment - E&O and contract manufacturer
liability" and "write-off of capitalized inventory fees" represent normal operating
expenses necessary to operate your business and are not consistent with the guidance in
Question 100.01 of the Division of Corporation Finance's Compliance & Disclosure
Interpretations on Non-GAAP Financial Measures. Please revise future filings to no
longer exclude these adjustments from any non-GAAP performance measure.
FirstName LastNameSteven Gatoff
Comapany NameInseego Corp.
April 23, 2024 Page 2
FirstName LastName
Steven Gatoff
Inseego Corp.
April 23, 2024
Page 2
Please contact Jeff Gordon at 202-551-3866 or Anne McConnell at 202-551-3709 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing