SEC Comment Letter for ALIGN TECHNOLOGY (ALGN) — Apr 29, 2022
ALIGN TECHNOLOGY INC
Date: April 29, 2022 · CIK: 0001097149 · Accession: 0000000000-22-004647
AI Filing Summary & Sentiment
File numbers found in text: 000-32259
Letter
United States securities and exchange commission logo April 29, 2022 Joseph M. Hogan President and Chief Executive Officer Align Technology, Inc. 410 North Scottsdale Road, Suite 1300 Tempe, Arizona 85281 Re:Align Technology, Inc. Form 10-K for the fiscal year ended December 31, 2021 Filed February 25, 2022 Response Dated April 21, 2022 File No. 000-32259 Dear Mr. Hogan : We have reviewed your April 21, 2022 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 this 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 this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our March 31, 2022 letter. Form 10-K for the Fiscal Year Ended December 31, 2021 Consolidated Financial Statements Revenue Recognition, page 68 1.We have reviewed your response to prior comment 1 and note that you estimate usage, which requires significant judgment. For each of the periods presented, please tell us your estimated usage rates. If multiple types of estimated usage rates are used, please explain how these were determined. In addition, tell us the approximate impact to revenue from any period over period changes in estimated usage rates. You may contact Christie Wong at 202-551-3684 or Michael Fay at 202-551-3812 if you have any questions.
FirstName LastNameJoseph M. Hogan Comapany NameAlign Technology, Inc. April 29, 2022 Page 2 FirstName LastName Joseph M. Hogan Align Technology, Inc. April 29, 2022 Page 2 Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
April 29, 2022
Joseph M. Hogan
President and Chief Executive Officer
Align Technology, Inc.
410 North Scottsdale Road, Suite 1300
Tempe, Arizona 85281
Re:Align Technology, Inc.
Form 10-K for the fiscal year ended December 31, 2021
Filed February 25, 2022
Response Dated April 21, 2022
File No. 000-32259
Dear Mr. Hogan :
We have reviewed your April 21, 2022 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 this 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 this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
March 31, 2022 letter.
Form 10-K for the Fiscal Year Ended December 31, 2021
Consolidated Financial Statements
Revenue Recognition, page 68
1.We have reviewed your response to prior comment 1 and note that you estimate usage,
which requires significant judgment. For each of the periods presented, please tell us your
estimated usage rates. If multiple types of estimated usage rates are used, please explain
how these were determined. In addition, tell us the approximate impact to revenue from
any period over period changes in estimated usage rates.
You may contact Christie Wong at 202-551-3684 or Michael Fay at 202-551-3812 if you
have any questions.
FirstName LastNameJoseph M. Hogan
Comapany NameAlign Technology, Inc.
April 29, 2022 Page 2
FirstName LastName
Joseph M. Hogan
Align Technology, Inc.
April 29, 2022
Page 2
Sincerely,
Division of Corporation Finance
Office of Life Sciences