SEC Comment Letter 0000000000-22-012398 to AMBARELLA INC (AMBA) (CIK 0001280263) (AMBA)
AMBARELLA INC (AMBA) (CIK 0001280263)
Date: Nov. 15, 2022 · CIK: 0001280263 · Accession: 0000000000-22-012398
AI Filing Summary & Sentiment
File numbers found in text: 001-35667
Letter
United States securities and exchange commission logo November 15, 2022 Brian C. White Chief Financial Officer Ambarella, Inc. 3101 Jay Street Santa Clara, California 95054 Re:Ambarella, Inc. Form 10-K for the Fiscal Year Ended January 31, 2022 Filed April 1, 2022 File No. 001-35667 Dear Brian C. White: 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 January 31, 2022 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 54 1.Please revise the discussion in future filings to describe the impact of the supply chain issues your company is having on your results of operations. Also, discuss any known trends or uncertainties on your results. Refer to Item 303(b)(2) of Regulation S-K. In this regard, we note that your management has been discussing the impact of supply chain issues during each of your last three quarterly earnings calls. 2.Revise your future filings to also discuss the changes in your revenue (i.e., increase or decrease) by volume and price. Refer to Item 303(b)(2)(iii) of Regulation S-K. In this regard, we note that your management has been providing similar information during each of your last three quarterly earnings calls.
FirstName LastNameBrian C. White Comapany NameAmbarella, Inc. November 15, 2022 Page 2 FirstName LastName Brian C. White Ambarella, Inc. November 15, 2022 Page 2 3.In future filings, expand your disclosure to identify specific actions planned or taken, if any, to mitigate inflationary pressures. Notes to the Consolidated Financial Statements Revenue Recognition, page 81 4.We note that during each of your last three quarterly earnings calls your management discussed your revenues by products and end-market. Please tell us your consideration of ASC 606-10-50-5 and 50-6, which call for disclosing disaggregated revenue by product or product families and end-market, in concluding that similar information should not be provided in this note. Otherwise, revise your future filings to comply. Similarly, revise your MD&A in future filings to provide a more detailed discussion of revenues by products and end-market. 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 Andri Carpenter at 202-551-3645 or Martin James, Senior Advisor, at 202-551-3671 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
November 15, 2022
Brian C. White
Chief Financial Officer
Ambarella, Inc.
3101 Jay Street
Santa Clara, California 95054
Re:Ambarella, Inc.
Form 10-K for the Fiscal Year Ended January 31, 2022
Filed April 1, 2022
File No. 001-35667
Dear Brian C. White:
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 January 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 54
1.Please revise the discussion in future filings to describe the impact of the supply chain
issues your company is having on your results of operations. Also, discuss any known
trends or uncertainties on your results. Refer to Item 303(b)(2) of Regulation S-K. In this
regard, we note that your management has been discussing the impact of supply chain
issues during each of your last three quarterly earnings calls.
2.Revise your future filings to also discuss the changes in your revenue (i.e., increase or
decrease) by volume and price. Refer to Item 303(b)(2)(iii) of Regulation S-K. In this
regard, we note that your management has been providing similar information during each
of your last three quarterly earnings calls.
FirstName LastNameBrian C. White
Comapany NameAmbarella, Inc.
November 15, 2022 Page 2
FirstName LastName
Brian C. White
Ambarella, Inc.
November 15, 2022
Page 2
3.In future filings, expand your disclosure to identify specific actions planned or taken, if
any, to mitigate inflationary pressures.
Notes to the Consolidated Financial Statements
Revenue Recognition, page 81
4.We note that during each of your last three quarterly earnings calls your management
discussed your revenues by products and end-market. Please tell us your consideration
of ASC 606-10-50-5 and 50-6, which call for disclosing disaggregated revenue by product
or product families and end-market, in concluding that similar information should not be
provided in this note. Otherwise, revise your future filings to comply. Similarly, revise
your MD&A in future filings to provide a more detailed discussion of revenues by
products and end-market.
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 Andri Carpenter at 202-551-3645 or Martin James, Senior Advisor, at
202-551-3671 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing