SEC Comment Letter for Vivint Smart Home, Inc. (CIK 0001713952) — Sep 22, 2022
Vivint Smart Home, Inc. (CIK 0001713952)
Date: Sept. 22, 2022 · CIK: 0001713952 · Accession: 0000000000-22-010432
AI Filing Summary & Sentiment
File numbers found in text: 001-38246
Letter
United States securities and exchange commission logo September 22, 2022 Dana Russell Chief Financial Officer Vivint Smart Home, Inc. 4931 North 300 West Provo , UT 84604 Re:Vivint Smart Home, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed March 1, 2022 File No. 001-38246 Dear Mr. Russell: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2021 Management's Discussion and Analysis of Financial Condition and Results of Operations. Adjusted EBITDA, page 60 1.We note that you are adjusting net loss by "Consumer financing fees" to arrive at Adjusted EBITDA. Please tell us the nature of the fees included in this adjustment, including your basis for reflecting them as a reduction to revenue on your Consolidated Statements of Operations. Additionally, tell us your consideration of Question 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameDana Russell Comapany NameVivint Smart Home, Inc. September 22, 2022 Page 2 FirstName LastName Dana Russell Vivint Smart Home, Inc. September 22, 2022 Page 2 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. You may contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551- 3307 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
September 22, 2022
Dana Russell
Chief Financial Officer
Vivint Smart Home, Inc.
4931 North 300 West
Provo , UT 84604
Re:Vivint Smart Home, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-38246
Dear Mr. Russell:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments. In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations.
Adjusted EBITDA, page 60
1.We note that you are adjusting net loss by "Consumer financing fees" to arrive at Adjusted
EBITDA. Please tell us the nature of the fees included in this adjustment, including your
basis for reflecting them as a reduction to revenue on your Consolidated Statements of
Operations. Additionally, tell us your consideration of Question 100.04 of the
Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.
FirstName LastNameDana Russell
Comapany NameVivint Smart Home, Inc.
September 22, 2022 Page 2
FirstName LastName
Dana Russell
Vivint Smart Home, Inc.
September 22, 2022
Page 2
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.
You may contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at 202-551-
3307 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services