SEC Comment Letter 0000000000-23-005469 to Charge Enterprises, Inc. (CIK 0001277250)
Charge Enterprises, Inc. (CIK 0001277250)
Date: May 23, 2023 · CIK: 0001277250 · Accession: 0000000000-23-005469
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File numbers found in text: 001-41354
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United States securities and exchange commission logo
May 23, 2023
Andrew Fox
Chief Executive Officer
Charge Enterprises, Inc.
125 Park Avenue, 25th Floor
New York, NY 10017
Re:Charge Enterprises, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed March 15, 2023
File No. 001-41354
Dear Andrew Fox:
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 Fiscal Year Ended December 31, 2022
Consolidated Statement of Operations, page F-5
1.Please revise to present the expense related to share-based payment arrangements in the
same line or lines as cash compensation paid to the same employees. Further, disclose the
amount of this expense included in the specific line items in a parenthetical note to the
appropriate income statement line items, on the cash flow statement, or in the footnotes to
the financial statements. Refer to SAB Topic 14F.
Notes to Consolidated Financial Statements
Note 2 Summary of significant accounting policies, page F-10
2.Revise to disclose the nature and types of costs included in costs of goods sold and
indicate whether this includes the applicable salaries and related benefits.
FirstName LastNameAndrew Fox
Comapany NameCharge Enterprises, Inc.
May 23, 2023 Page 2
FirstName LastName
Andrew Fox
Charge Enterprises, Inc.
May 23, 2023
Page 2
Revenue Recognition
Infrastructure, page F-12
3.We note your disclosures here, which are repeated on page F-18. Please revise to disclose
the nature of the infrastructure arrangements, types of services performed, typical terms
and contract length, and the specific performance obligations included. To the extent the
arrangements include more than one performance obligation, disclose how the transaction
price is allocated and how the estimated standalone selling price for each is determined.
Lastly, clarify what methods are used to recognize revenue, e.g. output or input methods,
and why the methods used provide a faithful depiction of the transfer of goods or
services. Refer to ASC 606-10-50-12 and 50-18.
Note 4 Revenue
Contract Balances, page F-19
4.Revise to include the amount of remaining performance obligations as of the end of the
reporting period and an explanation of when you expect to recognize such amounts as
revenue, on a quantitative basis or by using qualitative information. Refer to ASC 606-
10-50-13.
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 Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Jim Biehl, Chief Legal Officer