SEC Comment Letter for DEXCOM INC (DXCM) (CIK 0001093557) (DXCM) — Apr 21, 2022
DEXCOM INC (DXCM) (CIK 0001093557)
Date: April 21, 2022 · CIK: 0001093557 · Accession: 0000000000-22-004281
AI Filing Summary & Sentiment
File numbers found in text: 000-51222
Referenced dates: March 22, 2022
Letter
United States securities and exchange commission logo April 21, 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 Response Dated March 29, 2022 File No. 000-51222 Dear Mr. Sayer: We have reviewed your response to our comment letter 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 appreciate the information provided to us in your response letter and during the conference calls related to comment one in our letter dated March 22, 2022. We believe that your adjustments to exclude the non-cash collaborative research and development fee from non-GAAP operating income, non-GAAP adjusted EBITDA, non-GAAP net income and non-GAAP net income per share are inconsistent with Rule 100(b) of Regulation G. Please confirm to us that you will no longer include these adjustments in any non-GAAP financial measure presented in accordance with Item 10(e) of Regulation S-K or Regulation G.
FirstName LastNameKevin R. Sayer Comapany NameDEXCOM, INC. April 21, 2022 Page 2 FirstName LastName Kevin R. Sayer DEXCOM, INC. April 21, 2022 Page 2 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
April 21, 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
Response Dated March 29, 2022
File No. 000-51222
Dear Mr. Sayer:
We have reviewed your response to our comment letter 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 appreciate the information provided to us in your response letter and during the
conference calls related to comment one in our letter dated March 22, 2022. We believe
that your adjustments to exclude the non-cash collaborative research and development fee
from non-GAAP operating income, non-GAAP adjusted EBITDA, non-GAAP net
income and non-GAAP net income per share are inconsistent with Rule 100(b) of
Regulation G. Please confirm to us that you will no longer include these adjustments in
any non-GAAP financial measure presented in accordance with Item 10(e) of Regulation
S-K or Regulation G.
FirstName LastNameKevin R. Sayer
Comapany NameDEXCOM, INC.
April 21, 2022 Page 2
FirstName LastName
Kevin R. Sayer
DEXCOM, INC.
April 21, 2022
Page 2
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