Correspondence 0001628280-24-031892 from CALIX, INC (CALX) (CIK 0001406666) (CALX)
CALIX, INC (CALX) (CIK 0001406666)
Date: July 15, 2024 · CIK: 0001406666 · Accession: 0001628280-24-031892
AI Filing Summary & Sentiment
File numbers found in text: 001-34674
Referenced dates: July 2, 2024
Letter
VIA EDGAR Division of Corporation Finance Office of Technology Securities and Exchange Commission Re: Calix, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Form 8-K filed April 22, 2024 File No. 001-34674
Dear Inessa Kessman, Robert Littlepage:
This letter is submitted on behalf of Calix, Inc. (“Calix” or “Company”) in response to the comment of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) in its letter dated July 2, 2024 in connection with the above-referenced filings.
For convenience, we have set forth in bold the text of the Staff’s comment below followed by the Company’s response.
Form 8-K filed April 22, 2024
Exhibit 99.2, page 15
1. We note your response to prior comment 1. As the write-off of inventory and accrued liabilities related to excess components at suppliers related to your legacy product set appears to be a normal, recurring operating expense, please remove the non-GAAP adjustment for Inventory and component liability charges. Refer to Question 100.01 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
Response:
The Company respectfully advises the Staff that, in future filings, we will remove the non-GAAP adjustment for inventory and component liability charges related to our legacy product set.
Division of Corporation Finance
Office of Technology
July 15, 2024
Page 2
*****
Please do not hesitate to contact me at (408) 474-0052 if you have any questions or require further information.
Best regards,
/s/ Cory Sindelar
Show Raw Text
CORRESP 1 filename1.htm Document July 15, 2024 VIA EDGAR Inessa Kessman, Senior Staff Accountant Robert Littlepage, Accounting Branch Chief Division of Corporation Finance Office of Technology Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Calix, Inc. Form 10-K for the Fiscal Year Ended December 31, 2023 Form 8-K filed April 22, 2024 File No. 001-34674 Dear Inessa Kessman, Robert Littlepage: This letter is submitted on behalf of Calix, Inc. (“Calix” or “Company”) in response to the comment of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) in its letter dated July 2, 2024 in connection with the above-referenced filings. For convenience, we have set forth in bold the text of the Staff’s comment below followed by the Company’s response. Form 8-K filed April 22, 2024 Exhibit 99.2, page 15 1. We note your response to prior comment 1. As the write-off of inventory and accrued liabilities related to excess components at suppliers related to your legacy product set appears to be a normal, recurring operating expense, please remove the non-GAAP adjustment for Inventory and component liability charges. Refer to Question 100.01 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. Response: The Company respectfully advises the Staff that, in future filings, we will remove the non-GAAP adjustment for inventory and component liability charges related to our legacy product set. Division of Corporation Finance Office of Technology July 15, 2024 Page 2 ***** Please do not hesitate to contact me at (408) 474-0052 if you have any questions or require further information. Best regards, /s/ Cory Sindelar Cory Sindelar Chief Financial Officer Calix, Inc. cc: Michael Weening, President & CEO Doug McNitt, General Counsel (Calix, Inc.) Kathleen Wells, Esq. (Latham & Watkins LLP) Richard Imrisek Manoj Ramachandran (KPMG LLP)