SEC Comment Letter 0000000000-23-010533 to ASPEN AEROGELS INC (ASPN) (CIK 0001145986) (ASPN)
ASPEN AEROGELS INC (ASPN) (CIK 0001145986)
Date: Sept. 25, 2023 · CIK: 0001145986 · Accession: 0000000000-23-010533
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File numbers found in text: 001-36481
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United States securities and exchange commission logo
September 25, 2023
Donald Young
President and Chief Executive Officer
Aspen Aerogels Inc.
30 Forbes Road, Building B
Northborough, MA 01532
Re:Aspen Aerogels Inc.
Form 10-K for the Year Ended December 31, 2022
Filed March 16, 2023
File No. 001-36481
Dear Donald Young:
We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2022 filed March 16, 2023
Notes to Consolidated Financial Statements
(3) Revenue from Contracts with Customers, page 93
1.We note your revenue policy for subsea products and thermal barriers which state that you
recognize revenues at a point in time and over time utilizing the input method depending
on the terms of the contract. Please tell us your consideration of disclosing the revenues
recognized by each method. Refer to ASC 606-10-55-89 through 91. In addition, please
revise your disclosures in future filings to provide the disclosures required by ASC 606-
10-50-18b.
Exhibit 23.1, page 115
2.The consent references a report date of March 15, 2023; however, the audit report is dated
March 16, 2023. Please explain.
FirstName LastNameDonald Young
Comapany NameAspen Aerogels Inc.
September 25, 2023 Page 2
FirstName LastName
Donald Young
Aspen Aerogels Inc.
September 25, 2023
Page 2
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.
You may contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at 202-551-
3336 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services