SEC Comment Letter 0000000000-24-011071 to InMode Ltd. (INMD)
InMode Ltd.
Date: Sept. 30, 2024 · CIK: 0001742692 · Accession: 0000000000-24-011071
AI Filing Summary & Sentiment
File numbers found in text: 001-39016
Referenced dates: September 23, 2024
Letter
September 30, 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 Form 6-K Filed August 1, 2024 Response Letter Dated September 23, 2024 File No. 001-39016 Dear Yair Malca: We have reviewed your September 23, 2024 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 10, 2024 letter. Form 6-K Filed August 1, 2024 Exhibit 99.1 1.We note your response to comment 2. The pro forma non-GAAP measures you present do not represent non-GAAP measures of future financial performance contemplated by Item 10(e) of Regulation S-K or Regulation G. Rather, these non-GAAP measures include revenue and expenses in periods before the applicable recognition and measurement principles are met, and this results in measures that are inconsistent with Rule 100 of Regulation G. We do not believe the presentation of these measures is appropriate. Please revise future filings accordingly.
September 30, 2024 Page 2 Please contact Tracey Houser at 202-551-3736 or Al Pavot at 202-551-3738 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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September 30, 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
Form 6-K Filed August 1, 2024
Response Letter Dated September 23, 2024
File No. 001-39016
Dear Yair Malca:
We have reviewed your September 23, 2024 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 10, 2024
letter.
Form 6-K Filed August 1, 2024
Exhibit 99.1
1.We note your response to comment 2. The pro forma non-GAAP measures you present
do not represent non-GAAP measures of future financial performance contemplated by
Item 10(e) of Regulation S-K or Regulation G. Rather, these non-GAAP measures
include revenue and expenses in periods before the applicable recognition and
measurement principles are met, and this results in measures that are inconsistent with
Rule 100 of Regulation G. We do not believe the presentation of these measures is
appropriate. Please revise future filings accordingly.
September 30, 2024
Page 2
Please contact Tracey Houser at 202-551-3736 or Al Pavot at 202-551-3738 if you have
questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services