SEC Comment Letter for Maxeon Solar Technologies, Ltd. (MAXN) (CIK 0001796898) (MAXN) — Mar 12, 2020
Maxeon Solar Technologies, Ltd. (MAXN) (CIK 0001796898)
Date: March 12, 2020 · CIK: 0001796898 · Accession: 0000000000-20-002223
AI Filing Summary & Sentiment
Letter
March 12, 2020 Vichheka Heang Vice President and Corporate Controller Maxeon Solar Technologies, Pte. Ltd. 8 Marina Boulevard #05-02 Marina Bay Financial Centre 018981, Singapore Re:Maxeon Solar Technologies, Pte. Ltd. Draft Registration Statement on Form 20-F Filed December 20, 2019 CIK No. 0001796898 Dear Ms. Heang: We have reviewed your filing 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 and any amendment you may file in response to these comments, we may have additional comments. Amendment No.1 to Registration Statement on Form 20-F Reconciliation of Non-GAAP Financial Measures, page 90 1.We note your response to prior comment 2 and continue to believe the cost of above- market polysilicon adjustment represents an individually tailored accounting principle prohibited under Regulation G. Please revise. Refer to Question 100.04 of the Non-GAAP Compliance and Disclosure Interpretations. 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 Sisi Cheng at 202-551-5004 or John Cash at 202-551-3768 if you have questions regarding comments on the financial statements and related matters. Please contact
FirstName LastNameVichheka Heang Comapany NameMaxeon Solar Technologies, Pte. Ltd. March 12, 2020 Page 2 FirstName LastName Vichheka Heang Maxeon Solar Technologies, Pte. Ltd. March 12, 2020 Page 2 Sherry Haywood at 202-551-3345 or Jay Ingram at 202-551-3397 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing
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March 12, 2020
Vichheka Heang
Vice President and Corporate Controller
Maxeon Solar Technologies, Pte. Ltd.
8 Marina Boulevard #05-02
Marina Bay Financial Centre
018981, Singapore
Re:Maxeon Solar Technologies, Pte. Ltd.
Draft Registration Statement on Form 20-F
Filed December 20, 2019
CIK No. 0001796898
Dear Ms. Heang:
We have reviewed your filing 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 and any amendment you may file in response to these
comments, we may have additional comments.
Amendment No.1 to Registration Statement on Form 20-F
Reconciliation of Non-GAAP Financial Measures, page 90
1.We note your response to prior comment 2 and continue to believe the cost of above-
market polysilicon adjustment represents an individually tailored accounting principle
prohibited under Regulation G. Please revise. Refer to Question 100.04 of the Non-GAAP
Compliance and Disclosure Interpretations.
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 Sisi Cheng at 202-551-5004 or John Cash at 202-551-3768 if you have
questions regarding comments on the financial statements and related matters. Please contact
FirstName LastNameVichheka Heang
Comapany NameMaxeon Solar Technologies, Pte. Ltd.
March 12, 2020 Page 2
FirstName LastName
Vichheka Heang
Maxeon Solar Technologies, Pte. Ltd.
March 12, 2020
Page 2
Sherry Haywood at 202-551-3345 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing