SEC Comment Letter for MODEL N, INC. (CIK 0001118417) — Feb 19, 2020
MODEL N, INC. (CIK 0001118417)
Date: Feb. 19, 2020 · CIK: 0001118417 · Accession: 0000000000-20-001535
AI Filing Summary & Sentiment
File numbers found in text: 001-35840
Letter
February 19, 2020 David Barter Chief Financial Officer Model N, Inc. 777 Mariners Island Boulevard, Suite 300 San Mateo, California 94404 Re:Model N, Inc. Form 10-K for the Fiscal Year Ended September 30, 2019 Filed November 15, 2019 File No. 001-35840 Dear Mr. Barter: We have reviewed your filing 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. Form 10-K for the Fiscal Year Ended September 30, 2019 Consolidated Financial Statements Consolidated Statements of Operations, page 53 1.Please tell us the amount of revenue recognized from term-based software licenses during the periods presented and, if material, tell us how you considered presenting such revenues separately as product revenues. Refer to Rule 5-03 of Regulation S-X. 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 LastNameDavid Barter Comapany NameModel N, Inc. February 19, 2020 Page 2 FirstName LastName David Barter Model N, Inc. February 19, 2020 Page 2 You may contact David Edgar, Staff Accountant, at (202) 551-3459 or Melissa Kindelan, Staff Accountant at (202) 551-3564 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology
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February 19, 2020
David Barter
Chief Financial Officer
Model N, Inc.
777 Mariners Island Boulevard, Suite 300
San Mateo, California 94404
Re:Model N, Inc.
Form 10-K for the Fiscal Year Ended September 30, 2019
Filed November 15, 2019
File No. 001-35840
Dear Mr. Barter:
We have reviewed your filing 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.
Form 10-K for the Fiscal Year Ended September 30, 2019
Consolidated Financial Statements
Consolidated Statements of Operations, page 53
1.Please tell us the amount of revenue recognized from term-based software licenses during
the periods presented and, if material, tell us how you considered presenting such
revenues separately as product revenues. Refer to Rule 5-03 of Regulation S-X.
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 LastNameDavid Barter
Comapany NameModel N, Inc.
February 19, 2020 Page 2
FirstName LastName
David Barter
Model N, Inc.
February 19, 2020
Page 2
You may contact David Edgar, Staff Accountant, at (202) 551-3459 or Melissa Kindelan,
Staff Accountant at (202) 551-3564 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology