SEC Comment Letter for DEXCOM INC (DXCM) (CIK 0001093557) (DXCM) — Mar 22, 2022
DEXCOM INC (DXCM) (CIK 0001093557)
Date: March 22, 2022 · CIK: 0001093557 · Accession: 0000000000-22-003092
AI Filing Summary & Sentiment
File numbers found in text: 000-51222
Letter
United States securities and exchange commission logo March 22, 2022 Kevin R. Sayer President and Chief Executive Officer DEXCOM, INC. 6340 Sequence Drive San Diego, California 92121 Re:DEXCOM, INC. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed on February 14, 2022 Form 8-K Dated February 10, 2022 File No. 000-51222 Dear Mr. Sayer: We have limited our review of your filing to the financial statements and related disclosures 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 the 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 the comment, we may have additional comments. Form 8-K Dated February 10, 2022 Table E. Itemized Reconciliation Between GAAP and Non-GAAP Financial Measures, page 9 1.We note that you have excluded a non-cash collaborative research and development fee to arrive at non-GAAP operating income, non-GAAP adjusted EBITDA, non-GAAP net income and non-GAAP net income per share. Please tell us your consideration of the guidance in Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations Issued on April 4, 2018 for these adjustments.
FirstName LastNameKevin R. Sayer Comapany NameDEXCOM, INC. March 22, 2022 Page 2 FirstName LastName Kevin R. Sayer DEXCOM, INC. March 22, 2022 Page 2 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. You may contact Christie Wong at (202) 551-3684 or Kristin Lochhead, Senior Staff Accountant, at (202) 551-3664 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
March 22, 2022
Kevin R. Sayer
President and Chief Executive Officer
DEXCOM, INC.
6340 Sequence Drive
San Diego, California 92121
Re:DEXCOM, INC.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed on February 14, 2022
Form 8-K Dated February 10, 2022
File No. 000-51222
Dear Mr. Sayer:
We have limited our review of your filing to the financial statements and related
disclosures 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 the 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 the comment, we may have additional comments.
Form 8-K Dated February 10, 2022
Table E. Itemized Reconciliation Between GAAP and Non-GAAP Financial Measures, page 9
1.We note that you have excluded a non-cash collaborative research and development fee to
arrive at non-GAAP operating income, non-GAAP adjusted EBITDA, non-GAAP net
income and non-GAAP net income per share. Please tell us your consideration of the
guidance in Question 100.01 of the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations Issued on April 4, 2018 for these adjustments.
FirstName LastNameKevin R. Sayer
Comapany NameDEXCOM, INC.
March 22, 2022 Page 2
FirstName LastName
Kevin R. Sayer
DEXCOM, INC.
March 22, 2022
Page 2
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.
You may contact Christie Wong at (202) 551-3684 or Kristin Lochhead, Senior Staff
Accountant, at (202) 551-3664 with any questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences