SEC Comment Letter 0000000000-24-001161 to Fulgent Genetics, Inc. (FLGT) (CIK 0001674930) (FLGT)
Fulgent Genetics, Inc. (FLGT) (CIK 0001674930)
Date: Jan. 30, 2024 · CIK: 0001674930 · Accession: 0000000000-24-001161
AI Filing Summary & Sentiment
File numbers found in text: 001-37894
Referenced dates: November 1, 2023
Letter
United States securities and exchange commission logo January 30, 2024 Paul Kim Chief Financial Officer Fulgent Genetics, Inc. 4399 Santa Anita Avenue El Monte, California 91731 Re:Fulgent Genetics, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Form 10-Q for Fiscal Quarter Ended September 30, 2023 Response dated January 9, 2024 File No. 001-37894 Dear Paul Kim: We have reviewed your January 9, 2024 response to our comment letter and have the following comments. 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 November 21, 2023 letter. Form 10-K for Fiscal Year Ended December 31, 2022 Note 7. Reporting Segment and Geographic Information, page F-23 1.We note that you have identified four different revenue streams for your products and services offerings: (a) Precision Diagnostics; (b) Anatomic Pathology; (c) Pharma Services; and (d) COVID-19. We further note that your CODM and other members of management regularly receive and review revenues for these four revenue streams, budgets are created at the revenue stream level, and questions and other commentary of revenues and revenue trends are generated at this level during your earnings conference calls. As such, please provide the disclosures for each of these four revenue streams required by ASC 280-10-50-40.
FirstName LastNamePaul Kim Comapany NameFulgent Genetics, Inc. January 30, 2024 Page 2 FirstName LastName Paul Kim Fulgent Genetics, Inc. January 30, 2024 Page 2 Form 10-Q for Fiscal Quarter Ended September 30, 2023 Note 14. Goodwill and Acquisition-Related Intangible Assets, page 18 2.We note your response to comment 2. Specifically, we note that you did perform a quantitative analysis of your reporting unit using the market approach as of September 30, 2023 (i.e., step one for an interim impairment test). As such, disclosure here or within MD&A would provide investors with information about the qualitative factors considered that led you to perform the quantitative analysis and the results of that analysis. In this regard, we also refer you to comment 3 in our letter dated November 1, 2023, for disclosures to provide to investors regarding testing goodwill for impairment. Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at 202-551-3355 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
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United States securities and exchange commission logo
January 30, 2024
Paul Kim
Chief Financial Officer
Fulgent Genetics, Inc.
4399 Santa Anita Avenue
El Monte, California 91731
Re:Fulgent Genetics, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Form 10-Q for Fiscal Quarter Ended September 30, 2023
Response dated January 9, 2024
File No. 001-37894
Dear Paul Kim:
We have reviewed your January 9, 2024 response to our comment letter and have the
following comments.
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 November 21, 2023
letter.
Form 10-K for Fiscal Year Ended December 31, 2022
Note 7. Reporting Segment and Geographic Information, page F-23
1.We note that you have identified four different revenue streams for your products and
services offerings: (a) Precision Diagnostics; (b) Anatomic Pathology; (c) Pharma
Services; and (d) COVID-19. We further note that your CODM and other members of
management regularly receive and review revenues for these four revenue streams,
budgets are created at the revenue stream level, and questions and other commentary of
revenues and revenue trends are generated at this level during your earnings conference
calls. As such, please provide the disclosures for each of these four revenue streams
required by ASC 280-10-50-40.
FirstName LastNamePaul Kim
Comapany NameFulgent Genetics, Inc.
January 30, 2024 Page 2
FirstName LastName
Paul Kim
Fulgent Genetics, Inc.
January 30, 2024
Page 2
Form 10-Q for Fiscal Quarter Ended September 30, 2023
Note 14. Goodwill and Acquisition-Related Intangible Assets, page 18
2.We note your response to comment 2. Specifically, we note that you did perform a
quantitative analysis of your reporting unit using the market approach as of September 30,
2023 (i.e., step one for an interim impairment test). As such, disclosure here or within
MD&A would provide investors with information about the qualitative factors considered
that led you to perform the quantitative analysis and the results of that analysis. In this
regard, we also refer you to comment 3 in our letter dated November 1, 2023, for
disclosures to provide to investors regarding testing goodwill for impairment.
Please contact Tracey Houser at 202-551-3736 or Terence O'Brien at 202-551-3355 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services