SEC Comment Letter for SemiLEDs (LEDS) — Jan 12, 2026
SemiLEDs Corp
Date: Jan. 12, 2026 · CIK: 0001333822 · Accession: 0000000000-26-000340
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34992
Letter
Re: SemiLEDs Corp Form 10-K for the fiscal year ended August 31, 2025 Filed November 28, 2025 File No. 001-34992 Dear Christopher Lee:
January 12, 2026
Christopher Lee Chief Financial Officer SemiLEDs Corp 3F, No.11 Ke Jung Rd., Chu-Nan Site, Hsinchu Science Park, Chu-Nan 350 Miao-Li County Taiwan, R.O.C
We have limited our review of your filing to the financial statements and related disclosures 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.
Form 10-K for the fiscal year ended August 31, 2025 Notes to Consolidated Financial Statements Note 2 - Summary of Significant Accounting Policies Revenue Recognition, page 52
1. We note your new business initiative (i.e., buy-sell orders of equipment) has significantly impacted your revenues and cost of revenues. Please address the following items. In future filings, expand your disclosure (here and within your critical accounting policies and estimates on page 33) to clearly discuss buy-sell orders of equipment and your related accounting policies, including but not limited to gross versus net accounting treatment. Provide to us supplementally your assessment of ASC 606 in your determination of whether to present revenue on a gross or net basis. In this regard, ensure your January 12, 2026 Page 2
response addresses principal versus agent considerations as discussed in ASC 606-10-55-36 through 40.
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.
Please contact Jeff Gordon at 202-551-3866 or Hugh West at 202-551-3872 with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing
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<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> January 12, 2026 Christopher Lee Chief Financial Officer SemiLEDs Corp 3F, No.11 Ke Jung Rd., Chu-Nan Site, Hsinchu Science Park, Chu-Nan 350 Miao-Li County Taiwan, R.O.C Re: SemiLEDs Corp Form 10-K for the fiscal year ended August 31, 2025 Filed November 28, 2025 File No. 001-34992 Dear Christopher Lee: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K for the fiscal year ended August 31, 2025 Notes to Consolidated Financial Statements Note 2 - Summary of Significant Accounting Policies Revenue Recognition, page 52 1. We note your new business initiative (i.e., buy-sell orders of equipment) has significantly impacted your revenues and cost of revenues. Please address the following items. In future filings, expand your disclosure (here and within your critical accounting policies and estimates on page 33) to clearly discuss buy-sell orders of equipment and your related accounting policies, including but not limited to gross versus net accounting treatment. Provide to us supplementally your assessment of ASC 606 in your determination of whether to present revenue on a gross or net basis. In this regard, ensure your January 12, 2026 Page 2 response addresses principal versus agent considerations as discussed in ASC 606-10-55-36 through 40. 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. Please contact Jeff Gordon at 202-551-3866 or Hugh West at 202-551-3872 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing </TEXT> </DOCUMENT>