SEC Comment Letter 0000000000-23-013051 to Turtle Beach Corp (TBCH)
Turtle Beach Corp
Date: Nov. 30, 2023 · CIK: 0001493761 · Accession: 0000000000-23-013051
AI Filing Summary & Sentiment
File numbers found in text: 001-35465
Letter
United States securities and exchange commission logo November 30, 2023 John Hanson Chief Financial Officer Turtle Beach Corp 44 South Broadway 4th Floor White Plains, NY 10601 Re:Turtle Beach Corp Form 10-K for Fiscal Year Ended December 31, 2022 Response Dated October 6, 2023 File No. 001-35465 Dear John Hanson: We have reviewed your October 6, 2023 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 20, 2023 letter. Form 10-K for Fiscal Year Ended December 31, 2022 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Key Performance Indicators and Non-GAAP Measures, page 27 1.We have reviewed your response to prior comments 1 and 2. Based on your responses, the adjustments to your non-GAAP financial measures for employee and executive retention costs and for inventory and component related reserves appear to be normal operating expenses necessary to operate your business. As such, these adjustments are inconsistent with Question 100.01 of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations. Please revise your non-GAAP measures in future filings to remove these adjustments.
FirstName LastNameJohn Hanson Comapany NameTurtle Beach Corp November 30, 2023 Page 2 FirstName LastName John Hanson Turtle Beach Corp November 30, 2023 Page 2 Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
November 30, 2023
John Hanson
Chief Financial Officer
Turtle Beach Corp
44 South Broadway
4th Floor
White Plains, NY 10601
Re:Turtle Beach Corp
Form 10-K for Fiscal Year Ended December 31, 2022
Response Dated October 6, 2023
File No. 001-35465
Dear John Hanson:
We have reviewed your October 6, 2023 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 20,
2023 letter.
Form 10-K for Fiscal Year Ended December 31, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Performance Indicators and Non-GAAP Measures, page 27
1.We have reviewed your response to prior comments 1 and 2. Based on your responses,
the adjustments to your non-GAAP financial measures for employee and executive
retention costs and for inventory and component related reserves appear to be normal
operating expenses necessary to operate your business. As such, these adjustments are
inconsistent with Question 100.01 of the Non-GAAP Financial Measures Compliance
& Disclosure Interpretations. Please revise your non-GAAP measures in future filings to
remove these adjustments.
FirstName LastNameJohn Hanson
Comapany NameTurtle Beach Corp
November 30, 2023 Page 2
FirstName LastName
John Hanson
Turtle Beach Corp
November 30, 2023
Page 2
Please contact Mindy Hooker at 202-551-3732 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing