SEC Comment Letter 0000000000-24-010209 to InMode Ltd. (INMD)
InMode Ltd.
Date: Sept. 10, 2024 · CIK: 0001742692 · Accession: 0000000000-24-010209
AI Filing Summary & Sentiment
File numbers found in text: 001-39016
Letter
September 10, 2024 Yair Malca Chief Financial Officer InMode Ltd. Tavor Building, Sha’ar Yokneam P.O. Box 533 Yokneam, 2069206, Israel Re:InMode Ltd. Form 20-F for Fiscal Year Ended December 31, 2023 Filed February 13, 2024 Form 6-K Filed August 1, 2024 File No. 001-39016 Dear Yair Malca: We have limited our review of your filing to the financial statements and related disclosures 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. Form 20-F for Fiscal Year Ended December 31, 2023 Item 5. Operating and Financial Review and Prospects Operating Results Revenues, page 71 1.Given the material increase in 2023 revenue, please disclose the extent to which the increase was attributable to changes in sales volume or to changes in sales prices. See Item 5.A. of the form instructions. Form 6-K Filed August 1, 2024 Exhibit 99.1 We note your non-GAAP presentation of pro forma revenue, pro forma gross margins, pro forma net income, and pro forma earnings per diluted share for the purposes of 2.
September 10, 2024 Page 2 reflecting the sale of pre-orders of new platforms that were not yet delivered and did not meet the requirements for recognition under ASC 606 for the first two quarters of fiscal year 2024. Please provide us with a comprehensive explanation about how you considered the guidance in Rule 100 of Regulation G. 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. Please contact Tracey Houser at 202-551-3736 or Al Pavot at 202-551-3738 with any questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services
Show Raw Text
September 10, 2024
Yair Malca
Chief Financial Officer
InMode Ltd.
Tavor Building, Sha’ar Yokneam
P.O. Box 533
Yokneam, 2069206, Israel
Re:InMode Ltd.
Form 20-F for Fiscal Year Ended December 31, 2023
Filed February 13, 2024
Form 6-K Filed August 1, 2024
File No. 001-39016
Dear Yair Malca:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 20-F for Fiscal Year Ended December 31, 2023
Item 5. Operating and Financial Review and Prospects
Operating Results
Revenues, page 71
1.Given the material increase in 2023 revenue, please disclose the extent to which the
increase was attributable to changes in sales volume or to changes in sales prices. See
Item 5.A. of the form instructions.
Form 6-K Filed August 1, 2024
Exhibit 99.1
We note your non-GAAP presentation of pro forma revenue, pro forma gross margins,
pro forma net income, and pro forma earnings per diluted share for the purposes of 2.
September 10, 2024
Page 2
reflecting the sale of pre-orders of new platforms that were not yet delivered and did not
meet the requirements for recognition under ASC 606 for the first two quarters of fiscal
year 2024. Please provide us with a comprehensive explanation about how you
considered the guidance in Rule 100 of Regulation G.
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.
Please contact Tracey Houser at 202-551-3736 or Al Pavot at 202-551-3738 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services