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SEC Comment Letter 0000000000-24-011682 to CUTERA INC (CUTR) (CIK 0001162461)

CUTERA INC (CUTR) (CIK 0001162461)
Date: Oct. 17, 2024 · CIK: 0001162461 · Accession: 0000000000-24-011682

AI Filing Summary & Sentiment

File numbers found in text: 000-50644

Referenced dates: September 20, 2024

Date
October 17, 2024
Author
Services
Form
UPLOAD
Company
CUTERA INC (CUTR) (CIK 0001162461)

Letter

October 17, 2024 Stuart Drummond Interim Chief Financial Officer CUTERA INC 3240 Bayshore Boulevard Brisbane , California 94005 Re:CUTERA INC Form 10-K for Fiscal Year Ended December 31, 2023 Form 8-K Filed March 21, 2024 Response Letter Dated September 20, 2024 File No. 000-50644 Dear Stuart Drummond: We have reviewed your September 20, 2024 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 September 5, 2024 letter. Form 8-K Filed March 21, 2024 Exhibit 99.1 1.We note your response to comment 1. As the retention plan costs represent a normal, recurring operating expense, we request that you discontinue including this adjustment in your non-GAAP measures for any period presented in accordance with Question 100.01 of the Non-GAAP Compliance and Disclosure Interpretations. Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters.

October 17, 2024 Page 2

Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

Show Raw Text
October 17, 2024
Stuart Drummond
Interim Chief Financial Officer
CUTERA INC
3240 Bayshore Boulevard
Brisbane , California 94005
Re:CUTERA INC
Form 10-K for Fiscal Year Ended December 31, 2023
Form 8-K Filed March 21, 2024
Response Letter Dated September 20, 2024
File No. 000-50644
Dear Stuart Drummond:
            We have reviewed your September 20, 2024 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
September 5, 2024 letter.
Form 8-K Filed March 21, 2024
Exhibit 99.1
1.We note your response to comment 1. As the retention plan costs represent a normal,
recurring operating expense, we request that you discontinue including this
adjustment in your non-GAAP measures for any period presented in accordance
with Question 100.01 of the Non-GAAP Compliance and Disclosure Interpretations.
            Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.

October 17, 2024
Page 2

Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services