SEC Comment Letter 0000000000-23-013911 to IROBOT CORP (IRBT) (CIK 0001159167)
IROBOT CORP (IRBT) (CIK 0001159167)
Date: Dec. 20, 2023 · CIK: 0001159167 · Accession: 0000000000-23-013911
AI Filing Summary & Sentiment
File numbers found in text: 001-36414
Referenced dates: September 8, 2023
Letter
United States securities and exchange commission logo December 20, 2023 Julie Zeiler Chief Financial Officer IRobot Corporation 8 Crosby Drive Bedford , MA 01730 Re:IRobot Corporation Form 10-K for the fiscal year ended December 31, 2022 Filed February 14, 2023 Response Letter Dated September 8, 2023 File No. 001-36414 Dear Julie Zeiler: We have reviewed your September 8, 2023 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our August 8, 2023 letter. Form 10-K for the fiscal year ended December 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Key Financial Metrics and Non-GAAP Financial Measures, page 32 1.We reviewed your response to prior comment 1. We continue to believe IP litigation expenses are normal, recurring, cash operating expenses. Please revise future filing to not exclude IP litigation expenses from Non-GAAP financial measures in any current, future or prior period presented. Please refer to Questions 100.01 and 100.02 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameJulie Zeiler Comapany NameIRobot Corporation December 20, 2023 Page 2 FirstName LastName Julie Zeiler IRobot Corporation December 20, 2023 Page 2 Please contact Ernest Greene at 202-551-3733 or Anne McConnell at 202-551-3709 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
December 20, 2023
Julie Zeiler
Chief Financial Officer
IRobot Corporation
8 Crosby Drive
Bedford , MA 01730
Re:IRobot Corporation
Form 10-K for the fiscal year ended December 31, 2022
Filed February 14, 2023
Response Letter Dated September 8, 2023
File No. 001-36414
Dear Julie Zeiler:
We have reviewed your September 8, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our August 8,
2023 letter.
Form 10-K for the fiscal year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Financial Metrics and Non-GAAP Financial Measures, page 32
1.We reviewed your response to prior comment 1. We continue to believe IP litigation
expenses are normal, recurring, cash operating expenses. Please revise future filing to not
exclude IP litigation expenses from Non-GAAP financial measures in any current, future
or prior period presented. Please refer to Questions 100.01 and 100.02 of the Division of
Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures.
FirstName LastNameJulie Zeiler
Comapany NameIRobot Corporation
December 20, 2023 Page 2
FirstName LastName
Julie Zeiler
IRobot Corporation
December 20, 2023
Page 2
Please contact Ernest Greene at 202-551-3733 or Anne McConnell at 202-551-3709 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing