SEC Comment Letter for NLIGHT, INC. (LASR) (CIK 0001124796) (LASR) — Apr 12, 2018
NLIGHT, INC. (LASR) (CIK 0001124796)
Date: April 12, 2018 · CIK: 0001124796 · Accession: 0000000000-18-011073
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-224055
Letter
Mail Stop 3030 April 11, 2018 Scott H. Keeney President and Chief Executive Officer nLIGHT, Inc. 5408 Northeast 88th Street, Building E Vancouver, Washington 98665
Re: nLIGHT, Inc. Registration Statement on Form S -1 Filed March 30, 2018 File No. 333-224055
Dear Mr. Keeney :
We have reviewed your registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewin g any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments.
Comparison of Years Ended December 31, 2017 and 2016, page 54
1. Given the “offset” mentioned in your response to prior comment 2, it remains unclear how price decreases did not materially change your results of operations. Please expand to describe and quantify the “impact of price decreases on maturing products [which] was offset by growth in sales volumes and i ntroduction of new products.” Also expand to clarify why disclosing such information would be “artificial” and “could potentially confuse investors.”
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.
Scott H. Keeney nLIGHT, Inc. April 11 , 2018 Page 2
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective dat e of the registration statement.
You may contact David Burton at (202) 551 -3626 or Lynn Dicker , Senior Accountants, at (202) 551 -3616 if you have questions regarding comments on the financial statements and related matters. Please contact Tim Buchmiller at (202) 551 -3635 or Geoff Kruczek , Senior Attorney , at (202) 551-3641 with any other questions.
Sincerely,
/s/ Geoff Kruczek for
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Mail Stop 3030 April 11, 2018 Scott H. Keeney President and Chief Executive Officer nLIGHT, Inc. 5408 Northeast 88th Street, Building E Vancouver, Washington 98665 Re: nLIGHT, Inc. Registration Statement on Form S -1 Filed March 30, 2018 File No. 333-224055 Dear Mr. Keeney : We have reviewed your registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewin g any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Comparison of Years Ended December 31, 2017 and 2016, page 54 1. Given the “offset” mentioned in your response to prior comment 2, it remains unclear how price decreases did not materially change your results of operations. Please expand to describe and quantify the “impact of price decreases on maturing products [which] was offset by growth in sales volumes and i ntroduction of new products.” Also expand to clarify why disclosing such information would be “artificial” and “could potentially confuse investors.” 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. Scott H. Keeney nLIGHT, Inc. April 11 , 2018 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective dat e of the registration statement. You may contact David Burton at (202) 551 -3626 or Lynn Dicker , Senior Accountants, at (202) 551 -3616 if you have questions regarding comments on the financial statements and related matters. Please contact Tim Buchmiller at (202) 551 -3635 or Geoff Kruczek , Senior Attorney , at (202) 551-3641 with any other questions. Sincerely, /s/ Geoff Kruczek for Amanda Ravitz Assistant Director Office of Electronics and Machinery cc: Jeana S. Kim, Esq. Wilson Sonsini Goodrich & Rosati Professional Corporation