SEC Comment Letter 0000000000-24-012884 to IMMERSION CORP (IMMR) (CIK 0001058811)
IMMERSION CORP (IMMR) (CIK 0001058811)
Date: Nov. 20, 2024 · CIK: 0001058811 · Accession: 0000000000-24-012884
AI Filing Summary & Sentiment
File numbers found in text: 001-38334
Letter
November 20, 2024 J. Michael Dodson Chief Financial Officer Immersion Corporation 2999 N.E. 191st Street, Suite 610 Aventura, FL 33180 Re:Immersion Corporation Form 10-K for Fiscal Year Ended December 31, 2023 Form 8-K furnished August 20, 2024 Form 8-K/A furnished August 26, 2024 File No. 001-38334 Dear J. Michael Dodson: We have limited our review of your filings to the financial statements and related disclosures and have the following comments. 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. Form 8-K furnished August 20, 2024 Exhibit 99.1, page 1 1.We note the measure Immersion Corporation standalone Non-GAAP stockholders’ equity, which excludes the portion of Barnes & Noble Education’s net loss that is attributable to Immersion stockholders. As a result, this measure appears to substitute an individually tailored recognition method for those of GAAP. Please explain how you considered the guidance in Question 100.04 of the non-GAAP C&DIs or remove the measure. Form 8-K/A furnished August 26, 2024 Item 9.01. Financial Statements and Exhibits, page 2 You state the unaudited pro forma combined financial information for the year ended December 31, 2023 is attached as Exhibit 99.2. While such information is included in this Exhibit for the six months ended June 30, 2024, the information for year ended 2.
November 20, 2024 Page 2 December 31, 2023 is not. Please amend to include this information or advise. Refer to Rule 11-02(c)(2)(i) of Regulation S-X. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Melissa Kindelan at 202-551-3564 or Chris Dietz at 202-551-3408 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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November 20, 2024
J. Michael Dodson
Chief Financial Officer
Immersion Corporation
2999 N.E. 191st Street, Suite 610
Aventura, FL 33180
Re:Immersion Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
Form 8-K furnished August 20, 2024
Form 8-K/A furnished August 26, 2024
File No. 001-38334
Dear J. Michael Dodson:
We have limited our review of your filings to the financial statements and related
disclosures and have the following comments.
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.
Form 8-K furnished August 20, 2024
Exhibit 99.1, page 1
1.We note the measure Immersion Corporation standalone Non-GAAP stockholders’
equity, which excludes the portion of Barnes & Noble Education’s net loss that is
attributable to Immersion stockholders. As a result, this measure appears to substitute
an individually tailored recognition method for those of GAAP. Please explain how
you considered the guidance in Question 100.04 of the non-GAAP C&DIs or remove
the measure.
Form 8-K/A furnished August 26, 2024
Item 9.01. Financial Statements and Exhibits, page 2
You state the unaudited pro forma combined financial information for the year ended
December 31, 2023 is attached as Exhibit 99.2. While such information is included in
this Exhibit for the six months ended June 30, 2024, the information for year ended 2.
November 20, 2024
Page 2
December 31, 2023 is not. Please amend to include this information or advise. Refer
to Rule 11-02(c)(2)(i) of Regulation S-X.
In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
Please contact Melissa Kindelan at 202-551-3564 or Chris Dietz at 202-551-3408
with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology