Correspondence 0001704711-25-000009 from Funko, Inc. (FNKO)
Funko, Inc.
Date: Feb. 4, 2025 · CIK: 0001704711 · Accession: 0001704711-25-000009
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38274
Referenced dates: January 29, 2025
Letter
VIA EDGAR SUBMISSION Division of Corporation Finance Office of Manufacturing Securities and Exchange Commission Attention: Jeffrey Gordon and Ernest Greene Form 10-K for Fiscal Year Ended December 31, 2023 Form 8-K Furnished on November 7, 2024 Response dated January 15, 2025 File No. 001-38274
Dear Mr. Gordon and Mr. Greene:
Funko, Inc. (the “Company”) is pleased to respond to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated January 29, 2025. For ease of reference, the comment is repeated in italics below and followed by the Company’s response.
Form 10-K for the Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 70
1.We have read your response to prior comment 1. In regards to your adjustments related to (9) one-time disposal costs for finished goods held at offshore factories, (10) one-time disposal costs for unfinished goods held at offshore factories, and 11) inventory write-down, we continue to believe that these adjustments represent normal operating expenses related to your business and should not be eliminated from your Non-GAAP financial measures. Please revise future filings to not exclude these adjustments from your Non-GAAP performance measures. See Question 100.01 of the SEC's Non-GAAP Financial Measures Compliance and Disclosure Interpretation.
RESPONSE
The Company respectfully acknowledges the Staff’s comment, and the Company will remove the adjustments related to one-time disposal costs for finished goods held at offshore factories, one-time disposal costs for unfinished goods held at offshore factories, and inventory write-down from the Company’s Non-GAAP performance measures in its future filings with the Commission.
Please do not hesitate to telephone the undersigned at (425) 783-3616, ext. 267, if you have any questions regarding this response letter.
Very truly yours,
/s/ Yves Le Pendeven
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CORRESP 1 filename1.htm Document February 4, 2025 VIA EDGAR SUBMISSION Division of Corporation Finance Office of Manufacturing Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Jeffrey Gordon and Ernest Greene Re: Funko, Inc. Form 10-K for Fiscal Year Ended December 31, 2023 Form 8-K Furnished on November 7, 2024 Response dated January 15, 2025 File No. 001-38274 Dear Mr. Gordon and Mr. Greene: Funko, Inc. (the “Company”) is pleased to respond to the comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated January 29, 2025. For ease of reference, the comment is repeated in italics below and followed by the Company’s response. Form 10-K for the Fiscal Year Ended December 31, 2023 Management's Discussion and Analysis of Financial Condition and Results of Operations Non-GAAP Financial Measures, page 70 1.We have read your response to prior comment 1. In regards to your adjustments related to (9) one-time disposal costs for finished goods held at offshore factories, (10) one-time disposal costs for unfinished goods held at offshore factories, and 11) inventory write-down, we continue to believe that these adjustments represent normal operating expenses related to your business and should not be eliminated from your Non-GAAP financial measures. Please revise future filings to not exclude these adjustments from your Non-GAAP performance measures. See Question 100.01 of the SEC's Non-GAAP Financial Measures Compliance and Disclosure Interpretation. RESPONSE The Company respectfully acknowledges the Staff’s comment, and the Company will remove the adjustments related to one-time disposal costs for finished goods held at offshore factories, one-time disposal costs for unfinished goods held at offshore factories, and inventory write-down from the Company’s Non-GAAP performance measures in its future filings with the Commission. Please do not hesitate to telephone the undersigned at (425) 783-3616, ext. 267, if you have any questions regarding this response letter. Very truly yours, /s/ Yves Le Pendeven Yves Le Pendeven Chief Financial Officer