SecProbe.io

United States securities and exchange commission logo
May 6, 2024
Scott A. Roberts Roberts
Chief Financial Officer
HealthStream, Inc.
500 11th Avenue North, Suite 1000
Nashville , Tennessee 37203
Re:HealthStream, Inc.
Dear Scott A. Roberts Roberts:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 8-K filed on February 20, 2024
Exhibit 99.1
Financial Outlook for 2024, page 3
1.We noted your presentation of projected adjusted EBITDA for 2024 Financial Outlook in
Exhibit 99.1 without the presentation of the most comparable GAAP measure, projected
net income. Your presentation appears to give greater prominence to the non-GAAP
measure and does not comply with Item 10(e)(1)(i)(A) of Regulation S-K and Question
102.10 of the Division's Compliance & Disclosure Interpretations on Non- GAAP
Financial Measures which requires you to present the most directly comparable GAAP
measure with equal or greater prominence. Please revise your future presentations to
comply.
            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.

 FirstName LastNameScott A. Roberts Roberts
 Comapany NameHealthStream, Inc.
 May 6, 2024 Page 2
 FirstName LastName
Scott A. Roberts Roberts
HealthStream, Inc.
May 6, 2024
Page 2
            Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at 202-551-3488 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Technology