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SEC Comment Letter 0000000000-23-010644 to Xperi Inc. (XPER) (CIK 0001788999) (XPER)

Xperi Inc. (XPER) (CIK 0001788999)
Date: Sept. 27, 2023 · CIK: 0001788999 · Accession: 0000000000-23-010644

AI Filing Summary & Sentiment

File numbers found in text: 001-41486

Date
September 27, 2023
Author
Office of Technology
Form
UPLOAD
Company
Xperi Inc. (XPER) (CIK 0001788999)

Letter

United States securities and exchange commission logo September 27, 2023 Robert Andersen Chief Financial Officer Xperi Inc. 2190 Gold Street San Jose, CA 95002 Re:Xperi Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed March 6, 2023 File No. 001-41486 Dear Robert Andersen: We have reviewed your September 19, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 6, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Consolidated Financial Statements Consolidated Statements of Operations, page F-2 1.We note from your response to prior comment 1 that total revenue from services, which is the aggregation of non-recurring engineering ("NRE) services and advertising, accounted for less than 10% of total revenue for all periods presented. Please tell us what consideration was given to classifying your Technology Solutions arrangements as services. In this regard, these arrangements relate to the hosting and access to your platform which appear to be service arrangements. In your response, tell us the amount of revenues from Technology Solutions arrangements for the year ended December 31, 2022, including the extent to which such arrangements were accounted for as a single performance obligation or as multiple performance obligations.

FirstName LastNameRobert Andersen Comapany NameXperi Inc. September 27, 2023 Page 2 FirstName LastName Robert Andersen Xperi Inc. September 27, 2023 Page 2 You may contact Joyce Sweeney, Senior Staff Accountant, at 202-551-3449 or Christine Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding these comments. Sincerely, Division of Corporation Finance Office of Technology cc: Becky Marquez

Show Raw Text
United States securities and exchange commission logo
September 27, 2023
Robert Andersen
Chief Financial Officer
Xperi Inc.
2190 Gold Street
San Jose, CA 95002
Re:Xperi Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Filed March 6, 2023
File No. 001-41486
Dear Robert Andersen:
            We have reviewed your September 19, 2023 response to our comment letter and have the
following comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
September 6, 2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Consolidated Financial Statements
Consolidated Statements of Operations, page F-2
1.We note from your response to prior comment 1 that total revenue from services, which is
the aggregation of non-recurring engineering ("NRE) services and advertising, accounted
for less than 10% of total revenue for all periods presented.  Please tell us what
consideration was given to classifying your Technology Solutions arrangements as
services. In this regard, these arrangements relate to the hosting and access to your
platform which appear to be service arrangements.  In your response, tell us the amount of
revenues from Technology Solutions arrangements for the year ended December 31, 2022,
including the extent to which such arrangements were accounted for as a single
performance obligation or as multiple performance obligations.

 FirstName LastNameRobert Andersen
 Comapany NameXperi Inc.
 September 27, 2023 Page 2
 FirstName LastName
Robert Andersen
Xperi Inc.
September 27, 2023
Page 2
            You may contact Joyce Sweeney, Senior Staff Accountant, at 202-551-3449 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions regarding these
comments.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Becky Marquez